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There is no transfer of value where a close company makes a disposition of property to be held on trusts of the description specified in IHTA 1984, s 86(1) (see I5.630) and where the persons for whose benefit the trusts permit the property to be applied include all or most of either¹:

1. Ìý

   •ÌýÌýÌýÌý the employees or officers of the company, or

2. Ìý

   •ÌýÌýÌýÌý the employees or officers of the company or any one or more of its subsidiaries

Subsidiaryis defined in the Companies Act 2006, s 1159.

This wording seems to exclude from the section a disposition into a trust only for the benefit of the employees or officers of a subsidiary of the company making the disposition.

For the meaning of close company which see I6.102.

A transfer of value by a close company is chargeable to IHT only when apportioned to participators — see I3.102 and Division I6.1.

HMRC's view is that a trust for the benefit of all or most of