Any professional adviser (other than a barrister) who has been involved in setting up an offshore trust where the settlor is UK domiciled must send a section 218 Inheritance Tax Act 1984 notice to HMRC, unless the trust has been created by a will or an IHT100 account has been delivered to HMRC. Penalties apply if this notice is not sent to HMRC within three months of the creation of the trust.