IHTM30243 | Transfers and other events on or after 17 March 1987: settled property
From HM Revenue & Customs · Inheritance Tax Manual
Where:
the property is settled by the transfer
the tax is payable by the trustees of the settlement
and
the tax is borne by the trust fund
the tax is regarded as borne by the person(s) benefiting from the transfer for the purposes of IHTA84/S227(1)(b). This applies whether the trust is a relevant property trust (IHTM42161) or one in which there is a qualifying interest in possession (IHTM16061).