Nil Rate Band Availability

I am assisting the trustees with a TYA calculation and note the trust was originally set up by way of deed of variation.

The residuary beneficiary varied £250,000 of their share of their Father’s estate to be transferred into a discretionary trust. The estate was worth over £4m with only a nil rate band available and therefore, IHT was paid.

Assuming the deceased is the settlor for IHT purposes, is there a nil rate band available to the trustees when calculating the TYA charge?

Thanks,

Holly

Yes.
The nil rate band allowance available for the purpose of calculating ten year and exit charges will be reduced if the testator made chargeable lifetime transfers in the seven years prior to death, but the value of the estate itself is irrelevant.

Paul Davies
Clarke Willmott