there is an addition of value to a settled fund on or after 22 March 2006, and

the underlying interest in possession has subsisted since before 22 March 2006,

this will not result in any of the settled property becoming relevant property, provided that the addition really is one solely of value and is not an addition of property.

This is because:

under IHTA84/S43(2) there needs to be a disposition of property to create a settlement, and

an addition of value does not result from a disposition of property,

also, the increase in value derives from, or represents the property, that was settled before 22 March 2006.

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