Anti-avoidance provisions in IHTA 1984, s. 54A and 54B prevent settlors avoiding inheritance tax by settling property so that an individual with a much lower aggregation of previous chargeable transfers than the settlor is beneficially entitled to a qualifying interest in possession for a short period, which is then followed by trusts which are not subject to a qualifying interest in possession.

The circumstances in which the special charge applies are as follows (IHTA 1984, s. 54A(1), (2)):

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