17.7 The UK tax implications of establishing an excluded property trust
In what follows it is assumed that the settlor is UK resident but not UK domiciled when the trust is established.
17.7.1 Inheritance tax
Setting up the trust
For IHT purposes, a transfer of value (a gift) will normally take place at the time a trust is created, or when further amounts are added to a trust. However, with an excluded property trust no IHT will arise if the settlor is neither UK domiciled nor deemed UK domiciled when he or she creates the trust and ‘excluded property’ is transferred to the trust.