Two trusts are related under IHTA84/S62 only if
The trusts do not have to be discretionary to be related.
Related trusts are brought into cumulation for calculating the rate of tax on discretionary trust charges. (TYA: IHTM42085 , Proportionate: IHTM42114 )
IHTA84/S62 (2) states that 2 trusts are not related if the property in one or both of the trusts was held for charity without limit of time.
If IHTA84/S80 is in operation, the artificial later date applies in deciding whether trusts were made on the same day. ( IHTM42231)
