IHTM30122 | Liability in special cases: discretionary trust charges and heritage property
From HM Revenue & Customs · Inheritance Tax Manual
Where heritage property () is comprised in a settlement and has been exempted from the ten yearly charge, the persons liable for the tapered charge which may arise under are specified in . They are
the trustees of the settlement, and
any person for whose benefit any of the assets or income from it is applied at or after the time of the event causing the charge.