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HMRC internal manual

Inheritance Tax Manual

Employee benefit trusts: sponsored superannuation schemes: tax treatment

If an employee benefit trust or sub-trust (IHTM42970) was set up before 6 April 2006, you may need to determine whether it is a sponsored superannuation scheme (IHTM17039) before you can establish whether any tax charges arise on the trust.

Before 6 April 2006, a sponsored superannuation scheme fell within IHTA84/S151 and was excluded from being a relevant property trust by the provision in IHTA84/S58(d). Although this category of pension scheme was removed from the relevant Inheritance Tax exclusions with effect from 6 April 2006 there are transitional provisions for schemes that were in existence at that time. These provisions allow for a scheme that was within IHTA84/S151 immediately before 6 April 2006 to continue to be excluded from being relevant property, but only where no further contributions were made under the scheme on or after that date.

There are apportionment provisions if further contributions are made on or after 6 April 2006 but you are unlikely to see cases where the scheme trustees are not excluded from an Inheritance Tax charge. If you do come across a case where contributions have been made after 6 April 2006, you should refer it to Technical.