In Lexgreen Services Ltd v HMRC[2025] UKFTT 1019 (TC) (21 August) the First-tier Tribunal (FTT) held that a company can be liable for inheritance tax under IHTA 1984 s 201(1)(d) if that company is a ‘live company’ at the time of the relevant transfer.
This was a lead case pursuant to The Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules SI 2009/273 rule 18. The agreed question of law under rule 18 was whether a company that has made contributions to a trust is liable for any inheritance tax arising on the tenth anniversary of that trust as a result of IHTA 1984 s 201(1)(d).
The appellant Lexgreen Services Ltd established a remuneration trust in 2005 and over the following years settled sums into the trust totalling £6.5m. A Jersey-registered company was appointed...
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In Lexgreen Services Ltd v HMRC[2025] UKFTT 1019 (TC) (21 August) the First-tier Tribunal (FTT) held that a company can be liable for inheritance tax under IHTA 1984 s 201(1)(d) if that company is a ‘live company’ at the time of the relevant transfer.
This was a lead case pursuant to The Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules SI 2009/273 rule 18. The agreed question of law under rule 18 was whether a company that has made contributions to a trust is liable for any inheritance tax arising on the tenth anniversary of that trust as a result of IHTA 1984 s 201(1)(d).
The appellant Lexgreen Services Ltd established a remuneration trust in 2005 and over the following years settled sums into the trust totalling £6.5m. A Jersey-registered company was appointed...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
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