The transfer is effected pursuant to an appointment by the trustees, not the consentor, albeit with the consent of the consentor. Does this, however, mean that the provision of funds to the transferee trust have been provided. by the consentor?
Under IHTA 1984 s44, as you indicate, the. answer would seem to be “yes” but only by dint of treating the life tenant as possessing beneficial ownership of the funds (IHTA 1984 s49) which in reality is, of course, not true.
Unfortunately, Tobias, I fear my inadequate academic talents (such as they are!) leave me undecided and I look forward to a definitive opinion being posted by those far more knowledgeable than me.
Malcolm Finney