[IHTM42953] IHTM42953 – Employee benefit trusts: dispositions by a company: general
A charge to tax cannot arise on contributions that are made to an employee benefit trust (EBT) by a company that is not a close company (IHTM42955). This is because a chargeable transfer (IHTM04027) can only be made by an individual, IHTA does not generally apply to a public limited company; although see (IHTM42955).
Even so, where a company is the settlor of an EBT, the trust itself will be subject to Inheritance Tax in the normal way. The domicile of the settlor will be particularly relevant.