TC09618 - [2025] UKFTT 01019 (TC)

This is a case about the meaning of life.

Specifically, it is a case about the meaning of the word ‘life’ for the purposes of s 201(1)(d) Inheritance Tax Act 1984 (“IHTA”).

That section provides that the settlor of settled property is liable for the tax on a chargeable transfer, where the transfer is made during the ‘life’ of the settlor.

The settlor in this instance is a corporate entity. Does that entity have a ‘life’?

The Appellant argues that a corporate entity does not have a ‘life’, and therefore that the tax cannot be collected from a corporate settlor.

HMRC say that the section does apply to companies, and that the Appellant is liable for the tax.

For the reasons set out below I agree with HMRC and dismiss the appeal.