BPR, chargeable transfers and a ten year charge

I’m preparing IHT returns for the 10 year anniversary of a couple of trusts. Both were set up by the same settlor when he transferred in unquoted shares which qualified for BPR (value of each trust was £500,000). The trusts were set up one week apart. My question is on the second trust do I include the first trust as a chargeable transfer made by the settlor in the previous seven years (box 1.7 on the IHT100d) even though it was covered by BPR.
The trusts no longer qualify for BPR so it seems that by setting up two trusts rather than one we have obtained another nil rate band (assuming the first trust is a chargeable value of nil). Is this correct?
Many thanks

The transfers to be cumulated within the prior seven years are chargeable transfers (ie transfers of value, but exclude exempt transfers; IHTA 1984 s2). BPR involves a reduction in the value transferred and hence it is this reduced value which is cumulated.

Malcolm Finney

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