TC09618 - [2025] UKFTT 01019 (TC)

This case is a lead case, pursuant to rule 18 of The Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009.

The agreed issue of law under rule 18 is whether a company that has made contributions to a trust is liable for any inheritance tax arising on the 10th anniversary of that trust as a result of Inheritance Tax Act 1984 s201(d).

In the present case, if this Tribunal determines that a company can be liable under s 201(1)(d), it must then be determined whether the present Appellant is in fact liable for the charge in this case.

Put more simply, I must first decide whether a company can be liable, and then decide whether this company is liable.