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HMRC internal manual

Inheritance Tax Manual

Employee benefit trusts: conditions for relief: employees outside the UK

You will need to look at whole work force of a company when you consider whether the ‘all or most’ test is satisfied (IHTM42915).

If the company is:

  • an international company, or
  • a company employing people who live abroad

you may need to look at the statistics over a period of time, as you would in any case where the eligibility of beneficiaries changes and the over 50 per cent test must be applied. You should consider whether or not this test is met at the time an IHT charge arises but you do not need to keep the position under review (IHTM42915).