A cash contribution by C to the EOT in a later tax year will not qualify for relief by virtue of:

IHTA 1984, s. 10 (dispositions not intended to confer gratuitous benefit); or

IHTA 1984, s. 12 (dispositions allowable for corporation tax (CT) purposes).

In particular, such a contribution is not, under general principles, an allowable deduction for CT purposes if it is a distribution.

Furthermore, it may not qualify for exemption by virtue of s. 13 if the class of beneficiaries of the EOT does not then meet the ‘all or most [of the employees and directors]’ requirement.

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