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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Employee benefit trusts: sub-trusts: nil-rate band and calculation of tax

Generally, an employee benefit trust and any sub-trusts are one settlement (IHTM42974) as the sub-trusts are usually just an allocation of trust funds. In the event that any of the relevant property trust charges apply to a sub-trust (IHTM42975), any calculation will need to take into account all the property contained in that one settlement (the original employee benefit trust) and any sub-trusts. Then tax is calculated and charged on the event concerned in the normal way.

Where the sub-trusts are allocations of funds within a single trust, there is only one nil-rate band to take into account.