Special rules apply where a participator in a close company is a trustee (or body of trustees). The intention is to create a charge to tax which is equivalent to the charge on individual participators. The charge may be the result of an apportionment under IHTA 1984, s. 94, or else an alteration of capital charged under s. 98.

(1) Apportionment on trustees: s. 99

The nature of the charge on an apportionment under IHTA 1984, s. 94 will depend upon whether or not a qualifying interest in possession subsists in the settled property.

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