Paragraph 10 IHTA 1984

Section 64 (charge at ten-year anniversary) is amended as follows.

In subsection (1B), for the words from the beginning to “ten-year anniversary falls” substitute “Where the settlor of property comprised in a settlement meets the condition in subsection (1BZA)”.

After that subsection insert—

“(1BZA)

The condition is that the settlor—

(a)

is alive and is not a long-term UK resident immediately before the ten-year anniversary,

(b)

died on or after 6 April 2025 and was not a long-term UK resident immediately before their death, or

(c)

died before 6 April 2025 and was not domiciled in the United Kingdom when the property became comprised in the settlement.”

In subsection (1BA), for “subsection (1B)” substitute “subsection (1BZA)(c)”.