exercise by Trustees of overriding powers in a Will Trust

My clients are the Trustees of a Will Trust which gives a surviving spouse a Life Interest in the Residuary Estate. The Will Trust is subject to Trustees overriding powers allowing the Trustees to appoint capital within the Trust Fund to beneficiaries other than the Surviving Spouse. The Trustees are resolved to exercise their Overriding Powers such that Capital comprised in the Trust Fund is appointed to adult beneficiaries of the wider Will Trust. The surviving spouses consent is not required to this. Will the exercise of the Overriding Powers constitute a ‘Potentially Exempt Transfer’ even though the surviving spouses consent is not sought.

Mandy Kelly
Actons

Yes it will, but the trustees will be the ones to pay the tax if she dies within 7 years, so must reserve for that eventuality.

Simon Northcott

Yes - it would be a PET under s.52(1) IHTA.

Andrew Goodman
Osborne Clarke LLP