TC09618 - [2025] UKFTT 01019 (TC)

There is no real factual dispute between the parties, I have summarised the salient points below.

The Appellant was incorporated on 20 May 1996.

On 28 September 2005 the Appellant signed a trust deed, drafted by Baxendale Walker Solicitors, establishing the Lexgreen Services Limited Remuneration Trust (the “Trust”). Among other things, the trust deed named the Appellant as “the Founder”, appointed a company with a Jersey address as trustee, and stated that the Founder had settled a sum of £100 to the trust.

Over the following years, the Appellant settled further sums into the Trust totalling £6,525,000.

The Trust’s ten-year anniversary occurred on 28 September 2015.

It is common ground between the parties that a ten-year anniversary charge (under s 64 IHTA) has arisen. There is no dispute that the amount of the charge is £155,466.27 (plus any accrued interest).

On 22 December 2020, following correspondence between the parties, HMRC issued the “Notice of Determination” that is the subject of the present dispute.

The Noice of Determination provides (among other things) that

“The Settlor is liable to pay that Inheritance Tax together with interest at the statutory rate from 31 March 2016 until the date the Inheritance Tax is paid having regard to section 201 (1) (d) IHTA 1984.”

Following a statutory review, the Appellant notified its appeal to the Tribunal on 21 July 2021.