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HMRC internal manual

Inheritance Tax Manual

Employee benefit trusts: sub-trusts: revocation of sub-trust

Where a sub-trust which does not meet the requirements of IHTA84/S86 (IHTM42911) is revoked then, assuming that the main trust continues to meet the requirements of IHTA84/S86, the sub-trust fund will, once again, be held on those trusts.

As the sub-trust itself was a relevant property trust (IHTM42970) the revocation will give rise to an exit charge (IHTM42110) on the property ceasing to be relevant property under IHTA84/S65(1)(a), unless the trust property is shares or securities in a company and the provisions of IHTA84/S75 apply (IHTM42948).