HM Revenue & Customs (HMRC) has published new guidance on Inheritance Tax issues associated with Employee Benefit Trusts. This supersedes Revenue & Customs Brief 61/09.
The brief is aimed at agents and includes new material on ongoing Inheritance Tax liabilities of the trust and any sub-trusts it created and the taxation of income arising in offshore Employee Benefit Trusts as follows:
- Entry charges payable by a Close Company when it makes a contribution to a s86 Employee Benefit Trust
- Flat rate exit charge (s72) when property leaves a s86 Employee Benefit Trust
- Ten year and exit charges in respect of any sub-trusts
- Payment of ongoing Inheritance Tax liabilities
- Income Tax assessable under the transfer of asset legislation on income arising in offshore Employee Benefit Trusts
- Income Tax in relation to UK source income of offshore Employee Benefit Trusts
- Payment of ongoing trust Income Tax liabilities
Existing cases will be taken forward by HMRC on the basis of the views set out in this brief.
Links
Join us on LinkedIn 
