IHT charges in relevant property trusts: third consultation proposes settlement nil rate band

Practical Law UK Legal Update 8-570-5306 (Approx. 14 pages)

IHT charges in relevant property trusts: third consultation proposes settlement nil rate band

by Practical Law Private Client

Background

Inheritance tax charges in relevant property trusts

The inheritance tax (IHT) rules for relevant property trusts (RPTs) have three elements:

An entry charge. Lifetime gifts to RPTs are chargeable transfers at the lifetime rate of 20%. Gifts by will are chargeable transfers at the death rate of 40%. If a settlor dies within seven years of a lifetime transfer, the lifetime charge is recalculated at the death rate, with credit for tax already paid and reduced rates after three years. (Sections 2(1) and 7, Inheritance Tax Act 1984 (IHTA 1984).)
A ten-year anniversary (principal or periodic) charge. This is a charge on the value of the trust fund at each ten-year anniversary of its creation, at a maximum rate of 6%. The charge is reduced if assets are not relevant property for the full ten years. (Sections 64, 66 and 67, IHTA 1984.)
An exit (proportionate) charge. This is a charge on the reduction in value of a trust fund when assets cease to be relevant property. The charge is based on the number of quarter years that have elapsed in each ten-year period. The maximum rate is 5.85% (that is, 39/40 x 6%). (Sections 65, 68 and 69, IHTA 1984.)

Although these three types of charge are often referred to as elements of the same regime, the entry charge is an element of the regime that applies to transfers of value by individuals, whereas ten-year anniversary and exit charges (Chapter III charges) arise under a specific regime applying to RPTs and certain other trusts under Chapter III of Part III of IHTA 1984.

The broad aim of the RPT charging regime is that the three elements, taken together, should produce roughly the same amount of tax as if the assets remained in personal ownership and were transferred once a generation on death.

For more information about these charges, see Practice note, Inheritance tax: relevant property trusts: calculating the charge to tax. For information about when exit charges can arise in trusts other than RPTs, such as 18 to 25 trusts and accumulation and maintenance (A&M) trusts, see Practice note, Taxation of UK trusts: IHT and CGT summary tables.

Using the nil rate band in relevant property trusts

Calculating the rate of IHT that applies for Chapter III charges in an RPT involves calculating the IHT that would be charged on a hypothetical chargeable transfer (HCT) taking into account, amongst other things:

The value of relevant property in the trust at the date of a ten-year anniversary or (for an exit charge before the first ten-year anniversary) when the trust was created.
The value of assets in the trust that are not relevant property (non-relevant property) at the time they were added to the trust.
The value of assets in any related settlement on the date that settlement was created. (A related settlement is any trust created on the same day by the same settlor (section 62, IHTA 1984).)
The nil rate band (NRB) at the date of the charge.
The settlor's cumulative total of chargeable lifetime transfers in the seven years before the trust was created.

(Sections 66 to 69, IHTA 1984.)

Effectively, for the purposes of calculating the rate of IHT, each RPT has the NRB that applies at the date of the charge less the settlor's chargeable transfers in the seven years before the trust was created, unless it is a related settlement, in which case the available NRB is shared between them. This has given rise to a common estate planning technique, where a settlor creates separate trusts on different days so that each has its own NRB. This technique is particularly (but not exclusively) used for pilot trusts that a settlor creates during his lifetime to receive assets on his death (because if he creates more than one new trust in his will, these trusts will all take effect on the date of his death and so will be related settlements). HMRC's guidance on the general anti-abuse rule (GAAR) confirms that this type of planning is acceptable because it is long-established and was found to be effective in Inland Revenue v Rysaffe Trustee Company (CI) Ltd [2003] EWCA Civ 356 (see example D26 in Practice note, General anti-abuse rule (GAAR): Examples of abusive and non-abusive arrangements relevant to private client practitioners).

However, the settlor's cumulative total at the date each trust was created is always taken into account, even for Chapter III charges that arise more than seven years later, whereas for entry charges and lifetime gifts to individuals, the settlor's NRB is effectively renewed every seven years (section 7(1), IHTA 1984).

Following changes to the taxation of trusts in the Finance Act 2006 (FA 2006), many more trusts are subject to Chapter III charges. This is both because nearly all trusts created during a settlor's lifetime are now RPTs and because some pre-FA 2006 trusts (particularly A&M trusts) have become RPTs. This has highlighted the fact that the rules governing Chapter III charges are complicated and difficult to administer. Particular problems arise when historical data about a settlor's lifetime transfers and related settlements is not available because it was not known that this information would be needed when the trust was created.

For more information, see Practice notes:

Previous consultations

The government announced in the 2012 Budget that it would carry out a consultation on simplifying IHT charges in RPTs.

HMRC carried out an initial high level consultation from 13 July to 5 October 2012 (2012 consultation) (see Legal update, Inheritance tax: consultation on simplifying charges in relevant property trusts). On 11 December 2012, the government announced that a summary of responses and a more detailed consultation would be published in spring 2013 and confirmed this in the 2013 Budget.

HMRC published the summary of responses to the 2012 consultation on 22 March 2013 and ran a second consultation from 31 May to 23 August 2013 (2013 consultation) (see Legal update, IHT: Second consultation on simplifying charges in relevant property trusts).

Following a brief announcement in the 2013 Autumn Statement, on 10 December 2013, HMRC:

Published draft legislation for the Finance Bill 2014 (FB 2014) to:
- simplify filing and payment dates; and
- deem income to be accumulated, for the purposes of the ten-year anniversary charge, where it remained undistributed for more than five years .
These provisions will apply in respect of charges arising on or after 6 April 2014.
Confirmed that it would consult further on the following proposals, with a view to implementing them in the Finance Bill 2015:
- Splitting the NRB equally between a settlor's RPTs.
- Simplifying the calculation of Chapter III charges.
- The requirement for trustees to self assess Chapter III charges.

(See Legal update, Simplifying IHT charges in relevant property trusts: draft Finance Bill 2014 clauses.)

For further background (including consultation responses from professional bodies) and to follow the progress of the FB 2014 measures, see Private client tax legislation tracker 2013-14: Simplifying IHT charges in relevant property trusts.

HMRC publishes third consultation

On 6 June 2014, HMRC published its third consultation (2014 consultation).

HMRC now proposes to:

Introduce a separate NRB for RPTs.
Simplify the calculation of Chapter III charges. Trustees will be required to self assess these charges.
Introduce similar rules for 18 to 25 trusts.
Apply the new rules to Chapter III charges arising on or after 6 April 2015, with anti-forestalling provisions operating from 7 June 2014.

New settlement nil rate band for relevant property trusts

An additional NRB for individual settlors

HMRC proposes to give every individual a new settlement NRB (SNRB) in addition to his current NRB (personal NRB).

The upper limit for the SNRB will be the same as, and will change in line with, the upper limit for the personal NRB.

Each individual will have one SNRB during his lifetime. Unlike the personal NRB, it will not be renewed every seven years.

The SNRB will apply only for the purposes of calculating Chapter III charges in RPTs. Any entry charges that arise when a settlor makes a chargeable transfer of value by giving assets to an RPT, whether during his lifetime or on death, will be calculated using his personal NRB in the same way as they are now.

No SNRB for corporate settlors

Corporate settlors will not have an SNRB.

Currently, an RPT created by a corporate settlor usually has a full NRB available to it for Chapter III charges because companies cannot make chargeable transfers of value, although they can make transfers of value (sections 2(1) and 3(1), IHTA 1984). This means that there are no previous chargeable transfers to take into account unless the transfer of value is treated as being made by the participators in a close company (section 94, IHTA 1984) (see Practice note, Inheritance tax: overview: Gifts made by close companies).

RPTs created by corporate settlors (whether or not close companies) are subject to Chapter III charges in the same way as other trusts. However, many trusts created by corporate settlors in commercial contexts are outside the Chapter III regime because their assets are excluded from the definition of relevant property (for example, assets in employee benefit trusts and registered pension schemes) (section 58(1), IHTA 1984).

Statutory obligation for settlors to allocate their SNRB

Settlors will have a statutory obligation to elect how to divide their SNRB between the RPTs that they create. This proposal offers more flexibility than the suggestion in the 2013 consultation that a settlor's personal NRB should be divided equally between his RPTs (including pre-commencement RPTs). It is HMRC's response to concern that requiring trustees to find out about all a settlor's trusts would simply replace one set of complexities with another. Respondents pointed out that the information would have to be gathered at the time of every charge, whereas the historical information currently required only has to be established once.

The election to allocate the SNRB must be made in writing on a form provided by HMRC. The allocation must be expressed in percentage terms, because the value of the allocation will increase (or decrease) in line with any change to the upper limit of the SNRB.

A settlor can elect to allocate a percentage of his SNRB to a trust at any time from the date of creation to the date that payment is due for the first Chapter III charge arising in the trust. The settlor can amend or withdraw an allocation during that period, but cannot reduce the allocation after it has been used in the calculation of a Chapter III charge.

The settlor must notify the trustees of each RPT of the percentage of his SNRB allocated to that trust by providing them with a copy of the election. The trustees must be able to provide evidence of the election to HMRC (normally by keeping a copy of it). If the settlor does not provide a copy of an election to the trustees, the trustees must calculate Chapter III charges on the basis that no SNRB is available.

Adding assets to trusts

If a settlor adds assets to a trust and either the trust or the addition is subject to the new rules, he can elect to increase an existing SNRB allocation, or make a new allocation, if part of his SNRB remains available.

The SNRB allocation is relevant only to Chapter III charges. Any entry charge that arises on making the addition will continue to be calculated using the settlor's personal NRB.

The following rules will apply as they do now:

Additions to a trust by a different settlor will be treated as a separate trust for IHT purposes (section 44(2), IHTA 1984). Therefore, each settlor will have to make his own election if he wants to allocate part of his SNRB to his separate trust.
Assets transferred from one trust to another will be treated as remaining in the first trust for the purpose of Chapter III charges (section 81, IHTA 1984).

Reallocating the SNRB

It will be possible to reallocate the SNRB if assets cease to be relevant property because:

A trust is wholly wound up during the settlor's lifetime.
The assets become subject to charitable trusts.
A "vulnerable beneficiary" obtains a qualifying interest in possession. This presumably refers to a disabled person's interest, as the status of vulnerable person is not relevant to IHT, but only to income tax and capital gains tax. However, if the disabled person dies, the SNRB allocation will not automatically be restored in relation to any relevant property trusts that arise on his death. Therefore, the settlor may prefer not to reallocate it.

It is not possible to reallocate any SNRB if:

Only part of a trust is wound up.
A trust is wound up after the settlor's death.

It is unclear whether these restrictions also apply when assets become subject to charitable trusts or a disabled person's interest. We think it is likely that they do, because the rationale for reallocation in these cases is that the result is the same as if the trust had been wound up (paragraphs 3.22 and 3.23, 2014 consultation).

For existing trusts to which the SNRB does not apply, it is not possible to reallocate the settlor's personal NRB if the trust is wound up or if the assets become subject to charitable trusts or a disabled person's interest.

When the settlor dies

When the settlor dies, his personal representatives (PRs) will have two years to allocate any unused SNRB to trusts that the settlor has created either during his lifetime or in his will.

It is unclear whether a settlor can allocate, during his lifetime, a percentage of his SNRB to an RPT that he includes in his will, as the trust will not come into existence until his death. It appears that only the PRs may be able to do this (paragraph 3.13, 2014 consultation). If this is so, the settlor may want to leave guidance in a letter of wishes to cover the possibility that some of his SNRB will remain unallocated on his death.

The SNRB will be relevant only to Chapter III charges arising in will trusts following the settlor's death. The IHT charge on death will take into account the settlor's personal NRB as it does now.

Sanctions for overallocating the SNRB

If a settlor allocates more than 100% of his SNRB, he will face sanctions, which may include penalties. Trustees may also face sanctions if the SNRB is overstated or overclaimed as a result of their careless or deliberate actions.

If a settlor's PRs overclaim his SNRB, HMRC will reduce the claim in the chronological order of the elections made. It is unclear whether this means reverse chronological order (so that fewer claims are affected) and whether the same order will apply if a settlor overallocates the SNRB during his lifetime.

(For information about penalties, see Practice note, Tax penalties: overview.)

Simplifying calculation of Chapter III charges

Removing historical elements from rate of charge calculation

HMRC has confirmed its earlier proposals to simplify the calculation of Chapter III charges by:

Removing the following historical elements from the calculation of the rate of IHT for ten-year anniversary and exit charges:
- the value of the settlor's chargeable transfers in the seven years before creating the trust (but this will now only be for trusts to which the SNRB applies);
- the initial value of non-relevant property in the trust; and
- the initial value of assets in related settlements. (We think this means that the related settlements rule in section 62 of IHTA 1984 will become redundant.)
Using a flat rate of 6% as the basis for Chapter III charges. (The rate charged at ten-year anniversaries will always be 6%, but a lower settlement rate may still apply for exit charges: see HMRC examples of calculations.)

Therefore, our understanding is that when calculating the rate of IHT, the only information that trustees will need that may be more than ten years old will be:

For trusts to which the SNRB applies, the trust's SNRB allocation (if any).
For trusts that keep their existing NRB, the value of the settlor's chargeable transfers in the seven years before creating the trust.

For details of how this will work for new and existing trusts, see HMRC examples of calculations.

New requirement for trustees to self assess Chapter III charges

HMRC has also confirmed that trustees will have to self assess Chapter III charges after these changes are introduced. HMRC will provide guidance and online toolkits.

Possible extension to 18 to 25 trusts

Based on comments made in response to the 2013 consultation, HMRC proposes that the simplified method should also apply when calculating Chapter III charges in 18 to 25 trusts.

HMRC does not state whether 18 to 25 trusts would also share the settlor's SNRB. There are no examples of calculations for 18 to 25 trusts.

How the rules will apply to new and existing trusts

When the SNRB will apply

The SNRB will apply for the purpose of calculating Chapter III charges arising on or after 6 April 2015 in relation to:

Trusts created on or after 7 June 2014.
Additions made on or after 7 June 2014 to trusts created before that date. These additions will be treated as a separate fund within the trust.
Trusts created before 7 June 2014 where relevant property comes into being as a result of the terms of the trust being "amended" on or after that date.

Trusts created before 7 June 2014 to which no additions are made, and whose terms are not changed, on or after that date (grandfathered trusts) will retain the NRB available to them under the current rules.

It is unclear what is meant by the terms of a trust being "amended". For example, HMRC does not explain whether this would cover a change in trusts on which assets are held that results from:

Trustees exercising a power of appointment.
The terms of the trust when originally created, for example, where a qualifying interest in possession is followed by discretionary trusts and the life tenant dies on or after 7 June 2014.
A deed of variation.

It is also unclear whether the SNRB will apply only to the relevant property that comes into being as a result of the amendment (so that this has to be accounted for separately in the same way as added assets), or also to any assets in the trust that were relevant property before the amendment.

When simplified calculations will apply

The simplified calculation method using the flat 6% rate will apply to Chapter III charges arising on or after 6 April 2015 for all trusts, including trusts that are grandfathered for the purposes of the SNRB.

Summary of when SNRB and simplified calculations will apply

Trust details	Rules for Chapter III charges arising on or after 6 April 2015
Trust created before 7 June 2014: no additions and no amendment of terms on or after 7 June 2014	Simplified calculations apply but using the trust's existing NRB.
Trust created before 7 June 2014: addition(s) made on or after 7 June 2014	The SNRB and simplified calculations both apply in relation to the assets added on or after 7 June 2014, which are treated as a separate fund. Simplified calculations using the trust's existing NRB apply in relation to other assets.
Trust created before 7 June 2014: relevant property comes into being because terms of trust amended on or after 7 June 2014	The SNRB and simplified calculations both apply at least to the relevant property that came into being as a result of the amendment. Simplified calculations also apply to the assets that were relevant property before the amendment, but it is unclear whether the SNRB or the trust's existing NRB apply in relation to these assets.
Trust created on or after 7 June 2014	The SNRB and simplified calculations both apply.

This means that:

For trusts created on or after 7 June 2014, exit charges subject to the new rules can arise on or after 6 April 2015, but the first ten-year charges subject to the new rules will not arise until 2024.
For trusts created before 7 June 2014 to which additions are made or whose terms are changed on or after that date, both exit charges and ten-year charges subject to the new rules can arise on or after 6 April 2015, because ten-year anniversaries are counted from the date of creation of the trust.

For more detail about the effect of the commencement and anti-forestalling provisions on pilot trusts, see Summary of effect on pilot trusts.

HMRC examples of calculations

HMRC has provided examples of calculations using the simplified rules for trusts using the SNRB and examples of calculations using both the simplified rules and the old rules for grandfathered trusts (paragraphs 3.2 and 3.25, 2014 consultation).

These examples show that:

A flat rate of 6% will be used for ten-year anniversary charges, but a settlement rate will still have to be calculated for exit charges. For exit charges:
- before the first ten-year anniversary, the settlement rate is based on an HCT taxed at 6%; the HCT includes the value of the relevant property when the trust was created plus any additions since then, but not assets in related settlements or non-relevant property in the trust (Examples 3 and 5);
- after the first ten-year anniversary, the settlement rate is arrived at by expressing the tax charged at the last anniversary as a percentage of the value subject to tax at the anniversary (Examples 1 and 2).
We think this means that the settlement rate will only be the full 6% if there was no NRB to take into account (whether an SNRB allocation or the settlor's personal NRB) at the previous ten-year anniversary or in the HCT used to calculate the rate for an exit charge before the first ten-year anniversary.
As under the current rules, the settlement rate for exit charges after the first ten-year anniversary has to be recalculated if any relevant property has been added to the trust since the last anniversary (Example 2A). For trusts with an SNRB allocation, the recalculation will also take into account any increase in the allocation at the time of the addition (Example 2B) (see Adding assets to trusts and Practice note, Inheritance tax: relevant property trusts: calculating the charge to tax: What happens when property is added to the trust?).
The SNRB allocation or settlor's personal NRB available for a ten-year anniversary charge will still be reduced by the value of assets subject to exit charges during the ten-year period (Examples 4 and 5).
Chapter III charges will still take into account the length of time for which assets have been relevant property, based on quarter years (Examples 2-4).

The examples also show that the differences between the current and simplified calculation methods are as follows:

Using the current method, the settlor's personal NRB affects the rate of IHT that applies for Chapter III charges, but does not reduce the value of the assets subject to the charge. The charge will be nil if the rate is 0%. The rate will be 0% if the value of the HCT is less than the available NRB at the date of the charge (taking into account the historical information currently included).
Using the simplified method for ten-year anniversary charges, the SNRB or (for grandfathered trusts) the settlor's personal NRB can reduce the value of the relevant property subject to the ten-year anniversary charge, but does not affect the 6% rate of IHT. The charge will be nil if the value of the relevant property is within the available SNRB or NRB at the date of the anniversary.
Using the simplified method for exit charges, the SNRB or (for grandfathered trusts) the settlor's personal NRB can reduce the the settlement rate, but does not reduce the value of the assets subject to the charge. The charge will be nil if the settlement rate is 0%. The settlement rate will be 0%:
- for exit charges before the first ten-year anniversary, if the HCT used to calculate the rate is less than the available SNRB or NRB (not taking into account any of the historical information currently included); and
- for exit charges after the first ten-year anniversary, if the previous ten-year anniversary charge was nil (or would have been nil following a recalculation because relevant property has been added to the trust since the last ten-year anniversary).

Effect on pilot trusts

There are no special rules for pilot trusts, but they will be among the trusts most affected by the SNRB anti-forestalling provisions in relation to additions to existing trusts (see When the SNRB will apply).

Summary of effect on pilot trusts

The table below illustrates the effect on pilot trusts of the commencement and anti-forestalling provisions set out in Summary of when SNRB and simplified calculations will apply. It assumes that a settlor has set up an RPT with a small amount of cash (initial assets) with the intention that funds will be added to it at a later date (added assets).

For pilot trusts created before 7 June 2014, Chapter III charges arising soon after commencement may catch both clients and advisers unaware, particularly ten-year anniversary charges (as events giving rise to exit charges are more likely to be discussed in advance). For example, if a settlor created a pilot trust on 6 April 2005 to receive pension death benefits and dies in December 2014, both the SNRB and simplified calculations will apply to the added assets for the purposes of the ten-year anniversary charge that arises on 6 April 2015.

If a settlor has created more than one pilot trust, advisers will need to consider the position of each trust separately. If funds have been added to a trust on more than one occasion, they will also need to consider each addition separately.

Date trust created	Date funds added	Rules for Chapter III charges arising on or after 6 April 2015	When first Chapter III charges subject to new rules will arise
Before 7 June 2014.	Before 7 June 2014.	Simplified calculations using the trust's existing NRB apply to the initial assets and the added assets.	Both anniversary and exit charges subject to the new rules can arise from 6 April 2015.
Before 7 June 2014.	On or after 7 June 2014.	The SNRB and simplified calculations both apply to the added assets, which are treated as a separate fund. Simplified calculations using the trust's existing NRB apply to the initial assets.	Both anniversary and exit charges subject to the new rules can rise from 6 April 2015.
On or after 7 June 2014.	On or after 7 June 2014.	The SNRB and simplified calculations both apply to the initial assets and the added assets.	Exit charges subject to the new rules can arise from 6 April 2015, but anniversary charges subject to the new rules cannot arise before 7 June 2024.

Next steps

The consultation closes on 29 August 2014. HMRC is willing to arrange meetings with interested parties to discuss the consultation.

HMRC will publish draft legislation in autumn 2014 (presumably for inclusion in the Finance Bill 2015 as announced in HMRC's response to the 2013 consultation, although not stated in this consultation). HMRC will also publish a summary of responses.

To follow the progress of these measures, see Private client tax legislation tracker 2013-14: Simplifying IHT charges in relevant property trusts.

Comment

Over the course of HMRC's three consultations on this subject, the emphasis has shifted from "simplification" to "fairness". The original driver for this legislation appeared to be HMRC's own problems in dealing with the additional work caused by more trusts being subject to Chapter III charges and missing historical information. It was inevitable that division of the NRB would be addressed if the settlor's historical chargeable transfers were to be removed from the calculations, and it is not surprising that HMRC should aim to prevent the use of multiple nil rate bands. But it is not inherently fairer for the SNRB to be available only once rather than renewed every seven years in the same way as the personal NRB: it is a policy choice. It would have been more transparent if HMRC had announced that it had decided to take the opportunity to prevent the type of planning found to be lawful in Rysaffe and recognised not to be abusive in the GAAR guidance.

Although many existing trusts will be grandfathered in relation to the SNRB (which is a significant improvement on the 2013 consultation proposals), practitioners will need to take into account the anti-forestalling provisions when advising on any new trusts, additions to trusts or amendments to trusts (whatever that may turn out to mean) on or after 7 June 2014. They will also need to consider whether to take any action in relation to pilot trusts set up in the past where they may have no current retainer to advise the settlor or trustees, but where funds will be added on the settlor's death unless steps are taken. These tasks will be made more difficult because the precise form of the new rules will not be certain until the Finance Bill 2015 is enacted in just over a year's time.

Leaving aside the SNRB, the new method of calculation is more straightforward, particularly for ten-year anniversary charges. However, the proposals introduce new areas of complexity. For the foreseeable future, there will be parallel regimes for the calculation of Chapter III charges, depending on whether an RPT (and perhaps an 18 to 25 trust) retains an existing NRB or must share the SNRB. Different regimes may apply to different funds within the same trust. Record-keeping will be still more complicated if a trust has more than one settlor, with the possibility of multiple separate sets of calculations if each settlor has funds subject to different regimes.

Keeping track of SNRB allocations is also likely to cause headaches, as HMRC has placed the onus firmly on the settlor to do this. The settlor may well forget what he has done, particularly if there is a long interval between the creation of trusts, if he changes advisers or is not advised at all (for example, when using standard forms supplied by insurance companies). HMRC itself may not have a current record of allocations because it may only become aware of an allocation, and the amount of the allocation will only be confirmed, when the first Chapter III charge has to be reported for a trust. Respondents to the 2013 consultation pointed out that HMRC's original proposals might have resulted in no trustee, if properly advised, being able to sign a trust tax return because of uncertainty about its accuracy. The latest proposals may mean that some trustees, if properly advised, will be unable to claim any SNRB allocation because of uncertainty about what the settlor has done previously.

There will be winners and losers under the new proposals. Individuals with the resources and intention to use their personal nil rate bands to create trusts every seven years will lose out going forward, although they can take steps to ensure that existing trusts are grandfathered. Individuals who have no personal NRB available and do not intend to create multiple trusts will benefit from having the new SNRB. Chapter III charges will be lower in some trusts (particularly where related settlements and non-relevant property were significant) and higher in others (particularly where no SNRB is available or there is no evidence of an allocation).

Having changed its proposals about the NRB following the 2013 consultation, it seems unlikely that HMRC will make substantial changes to those set out in the current consultation. However, much detail remains to be clarified in the draft legislation to be published in the autumn.

Source

HMRC: Inheritance tax: A fairer way of calculating trust charges.

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