Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Employee benefit trusts: conditions for relief: trustees' remuneration

Some employee benefit trusts contain a provision that enables the trustees to charge a fixed fee or some other remuneration for their services. If the trustee is a corporation or someone who is not an employee of the company, this could be an application of the settled property which would infringe IHTA84/S86(1).

In practice, if the provision enables the trustee to charge no more than the going rate for their services you should not regard this as permitting an application of the settled property for their benefit.