As regards settlements made on or after 27 March 1974, the rules for computing the tax on the second and subsequent anniversaries are the same as for the first one. However, it should be remembered that only those existing charges within the ten years before each anniversary are taken into account.


The facts are the same as in the example in ¶62525 above. In February 2022, the trustees appoint £50,000 (gross) to Donald out of the discretionary part of the fund. Assume on 8 October 2031, the relevant property fund is worth £900,000.

The ten-year charge in 2031 will be calculated as follows (assuming the threshold remains unchanged).

Step 1

Hypothetical transfer

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