Property (
IHTM04030) held on discretionary trusts
under which, for any defined period, or indefinitely, the property
can be applied only for the benefit of employees in a particular
occupation or of a particular firm, or the relatives or dependants
of such employees, IHTA84/S86, is not relevant property, IHTA84/S58
(1)(b), and so is not liable to the ten year or proportionate
charge.
Distributions to the employees or their relatives or
dependants are normally exempt.
Tax is charged when property ceases to be held on employee
trusts or when the trustees make a disposition (
IHTM04023) which reduces the value of
the property so held, or when payments are made to participators,
IHTA84/S72 (2).
Property subject to an interest in possession is disregarded
if the interest extends to less than 5% of the property, IHTA84/S86
(4)(b).
Under IHTA84/S70 (4) relief for dispositions not intended to
confer bounty (
IHTM04161) and a grant of a tenancy of
agricultural property (
IHTM04230) can apply.
The tax treatment of trusts for newspaper publishing
companies or newspaper holdings companies follows the treatment of
for employee trusts, IHTA84/S87.
