As stated above, a transfer is exempt only if the persons for whose benefit the trusts permit the settled property to be applied include all or most of the persons employed or holding office with the company. The exemption is further restricted by IHTA 1984,. s. 28(4), which disqualifies trusts which permit any of the settled property to be applied at any time (whether during the subsistence of the s. 86 trusts or later) for the benefit of any of the following:

(1)a participator in the company;

(2)a participator in any close company which has made a disposition whereby property became comprised in the same settlement, and which, but for s. 13, would have been a transfer of value;

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