We have a situation whereby the Company has paid the trustees’ fees. These will be regarded as contributions to the Scheme and the IHT benefits would only apply in relation to the 5 April 2006 benefits. The Scheme’s growth in excess of RPI from 5 April 2006 is subject to the ‘relevant property regime’.
The consequence of this is that part of the Scheme would be subject to 10 yearly anniversary IHT charges, and IHT exit charges on payments out of the Scheme.
The 10 yearly anniversary IHT charges are calculated with reference to the date the Scheme was established. In this case 28 March 1994. Therefore the 10 year anniversary on 28 March 2014 is the first since 5 April 2006.
In this case there was a distribution in 2009.
I’d welcome any views on how this should be included in the 10 year anniversary charge calculation with particular reference to the RPI.