IHTM42921 | Employee benefit trusts: conditions for relief: investigation

From HM Revenue & Customs · Inheritance Tax Manual

When investigating whether or not an employee benefit trust satisfies the requirements of , there are a number of points to look out for. These are:

  • non-qualifying beneficiaries ()

  • former employees ()

  • probationers ()

  • partnerships ()

  • trustees’ remuneration ()

  • splitting funds or ‘hiving off’ ()

  • employees outside the UK ()

  • company groups and subsidiaries ()

  • share price schemes ()

  • part-time staff and casual labour ()

  • best interests of the company ()

  • insolvency ()

  • consultants ()

  • payment of tax liabilities out of trust funds ()

  • power to transfer funds to another settlement ()

  • direction to waive dividends ()