The benefits on creation are as noted by Paul. As it is an RPT it will continue to benefit from there being no chargeable event for IHT on the death of any beneficiary, including a life tenant, and of thus continuing to avoid aggregation with the free estate of a deceased life tenant or with any IPDI fund deemed to be his/hers.
The periodic IHT ten year anniversary chargeable events continue to apply, measured at intervals from a date in 1960, but the trustees can decide whether to manage those by distributing before or after the next such event (if still to occur in the rest of 2020), with CGT hold-over relief if useful, or doing nothing at present.
The main IHT downside of the 2006 reforms was to make a transfer into a new life tenant trust a chargeable transfer rather than a PET, with a silver lining of CGT hold-over relief for non-business non-cash assets; allowing such assets to go in and come out with that relief to a beneficiary, who could then benefit from the step up to market value on his own death or claim the relief again on a subsequent transfer that was not a PET.
In my experience few make chargeable transfers into RPTs unless covered by their nil rate band but there is the opportunity of a future tax-free distribution (whatever the then value of the distributed asset) before the first 10 year anniversary event or for management of later trust charges, utilising the IHT nil rate band and the seriously low 6% maximum marginal rate and possibly CGT hold-over.
Planning viability thus remains despite the demise of the multiplication of trusts with separate NRBs, although trusts are roundly detested by HMRC and HMG. Trusts may be targeted by any future IHT reforms but the insightful report by the APPG acknowledges that they do present some challenges to any replacement of IHT (which they advocate and I support in principle).
Politicians’ attention span cannot cope with the necessarily extended horizon of many trustees (or indeed much else more than 5 years out) and HMRC’s psychopathology prevents their acknowledging that any given trust might exist for a purpose other than the vile nefarious deprivation of the Exchequer.
But, as I say to my medical acquaintances, how would they like it if human anatomy and physiology was totally transformed regularly over future 3 year intervals as is the tax system?