½Û×ÓÊÓÆµ

Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.3 Settlements within the relevant property regime /Tax treatment of relevant property trusts / I5.307 Depreciatory transactions in relevant property trusts
Commentary

I5.307 Depreciatory transactions in relevant property trusts

IHT, trusts and estates

Subject to the exceptions mentioned in I5.331–I5.342, if the trustees of the settlement make a disposition, a result of which the value of relevant property in the settlement is less than it would otherwise have been, there is a charge to IHT1 at the rates determined as described in I5.3132.

This prescribes the same rules for taxing depreciatory dispositions made by trustees of relevant property as those which relate to dispositions by individuals (I3.111–I3.114). The use of the word 'disposition' means that the following will be charged to tax:

  1. Ìý

    •ÌýÌýÌýÌý a disposition effected by associated operations3 (see I3.115 onwards)

  2. Ìý

    •ÌýÌýÌýÌý an alteration in, or in rights attached to, a close company's unquoted capital, where the trustees are participators (this will be an occasion of charge as a disposition by

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial

Web page updated on 17 Mar 2025 16:42