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Conclusions
Conclusion
For the reasons set out above, I find that:
The answer to the common issue under rule 18 is: yes, a company that has made contributions to a trust can be liable for any inheritance tax arising on the 10th anniversary of that trust as a result of Inheritance Tax Act 1984 s201(d), if that company is a live company at the time of the relevant transfer.
The Appellant was a live company at all material times
I therefore dismiss the appeal.
Right to apply for permission to appeal
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 21st AUGUST 2025