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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.2 Settlements with a qualifying interest in possession (QIIP) /Calculation of IHT for qualifying interests in possession (QIIPs) / I5.281 Termination during lifetime of life tenant
Commentary

I5.281 Termination during lifetime of life tenant

IHT, trusts and estates

I5.281 Termination during lifetime of life tenant

If a qualifying interest in possession (QIIP) comes to an end during the life of an interest beneficiary (the life tenant) and none of the exemptions from charge described or referred to in I5.251 apply, then there is a chargeable transfer treated as made by the life tenant.

The value on which IHT is charged is the value of the settled property that was subject to the interest (see I5.228).

Calculation of IHT

The general rules for calculating IHT on lifetime transfers of value therefore apply.

The transfer may be a chargeable lifetime transfer (CLT) because, for example, the remainder interest passes to discretionary trusts on the termination of the QIIP. In this case the rules for calculating the IHT described in I3.521 onwards are applicable.

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Web page updated on 17 Mar 2025 16:47