Settlor Interest Trust

I am dealing with a matter whereby the clients (husband and wife) in 2013 via a Will writing firm have set up a ‘Family Trust’.

Mr and Mrs are settlors.

Mr, Mrs and two of their children are trustees.

Mr, Mrs, one of their children and anyone else added with the consent of the settlors or beneficiaries if settlors deceased or incapacitated are named as beneficiaries.

The terms of the trust also state that any income from the trust should be paid to the settlors during their lifetime. It is clearly a settlor interested trust, and I am unsure why they were ever advised to do this.

The trust fund is defined in the trust instrument as ‘property specified in the first schedule’ and ‘property transferred to the Trustees to hold on the terms of this trust’ . The first schedule details their main residence and then any sums deposited in a trust bank account.

The property was never transferred into the name of the trustees. It remains in Mr and Mrs name from when they purchased it but there is a restriction on the property to say no disposition without declaration/certificate that it is in accordance with the trust and names all the trustees.

The trust has never been registered, no entry charges paid or ten yearly anniversary charge. The client doesn’t even understand what he has entered into. They were sold the typical dream of not having to pay any IHT!

Is there anyway out of the trust with exit charges given the property was never transferred to the trustees? Or are they stuck with the trust and ongoing charges and then it being a GWROB on death.

Any help greatly appreciated. Thank you!

This kind of trust is appallingly useless for fiscal and all other legal purposes where the main residence is a trust asset and the combined estates are currently and prospectively of low value so that IHT was a minor or zero concern and alternative Will provisions were much better.

Equity employs a doctrine of mistake which can be invoked to nullify a gift in circumstances where it would be unconscionable to allow it to stand. This doctrine has been most graphically explored in the context of trustees making an appointment but it is equally applicable to creating a trust. The leading case is Pitt v Holt [2013] UKSC 26.

Much will depend on what advice the clients were given at the time but the chances are that they relied solely on the sales pitch of an adviser who can be demonstrated to have been patently unqualified to advise. Drafting a deed is a reserved activity. Who did that and who made the Land Registry entry? This seems to be the only external evidence of the existence of the trust.

In 2013 the RNRB would not have been in force or contemplation, and throwing that away would otherwise have been a big nail in the trust’s coffin. But the GROB situation alone is a ridiculous feature, especially during the initial 7 year survival period, and if not fully explained (very likely) would be another such big nail.

HMRC will not generally accept that a nullifying mistake has occurred unless a Court has decided that because it is a discretionary competence. Securing that will be expensive as to costs. It may be better to fully distribute the trust and accept the 2023 TYA charge. There are probably 2 trusts under s.44(2) and hopefully there was no entry charge because NRBs were available.

Certainly you should analyse exactly what the tax consequences and other costs would be. The removal of the GROB would be a PET, which risk might be still insurable cost-effectively, but the RNRB would become immediately available. There should be no CGT because of PPRR. Usually action against the will writer can be expected to be a waste of time and money but at least should be considered and threatened and even claimed if practicable.

Will writers provide a laudable service where they restrict their activities to encouraging impecunious individuals to make a Will cheaply so that they die more tidily. But they are a menace when they inveigle gullible people into sophisticated arrangements they do not themselves understand and are plainly unsuitable compared with the alternatives. They are also invariably not worth powder and shot even if the cause of action, limitation and evidence are cogent and often they are not. Their clients are however often expert practitioners of false economy who will not spend money on a proper adviser that they will cheerfully lay out on a new suite of furniture or a third annual foreign holiday. Volenti non fit injuria. These and my clientele were completely mutually exclusive though I assisted the repentant victims. I think we have gone far enough in regulating the good to protect the foolish and the wicked from themselves.

Jack Harper

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See (or rather hear) BBC Money Box programme of 20/9/25.

I agree with all of the above, but to add a little context to the possible motive behind the establishment of this trust, I believe it will likely have been to avoid the possibility of care home fees eroding / extinguishing the value of the property.

As a financial adviser, I have seen numerous clients that have been sold these ‘asset / family protection trusts’ on the basis that if they don’t directly own the property then it will not come inside a means test. They rarely understand what they have entered into, and may have been incorrectly sold ‘IHT savings’ as a front to disguise the real motive, in an attempt to side-skirt Deliberate Deprivation of Assets rules.

By it’s definition, if the planning is to protect the home from being used for care fees, then this would fall foul of Deliberate Deprivation of Assets rules and the home should be brought back inside the means test, regardless of the time period that has passed between the settlement and the means test.

I have also seen clients do this where there was no chance that they would ever have been self-funders for care fees due to guaranteed income levels. It was blanket sales rather than advice.

There are a number of scandals regarding this type of arrangement that are receiving media attention, particularly where the solicitors that first advised on it named themselves as trustees, listed themselves at the land registry, and their businesses subsequently went bust. It’s worth googling ‘McClures Solicitors Family Protection Trust’ to have a read about the issues!

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A post was split to a new topic: Settlor Interest Trust - What needs to accompany the AP1 and Deed of Appointment and Retirement?

To be fair, these trusts used to be effective in protecting against care fees. At least half the proiperty would be guaranteed protection against the survivor’s care fees (although a FLIT in the wills would achieve the same result). As for the other half the guidance issued to local authorities in the past was that provided the transaction was over three years prior to the resident going into care, the resident was in good health and local authority care was not in contemplation at that time of the transaction then the local authority should not take the asset into account. So these trusts could be effective in protecting against care fees. In Wales (where I work) local authority care legislation is now devolved and I don’t believe the same guidance is in place (I’ve no idea if it is still in place in England).

Many low income clients have little more than their home to pass on and are terrified that care fees will strip them of their only asset. So it is understandable that they explore such options. In fact, I have seen several cases (not my own) where such trusts have provided full protection. Personally, I advise clients that will FLITs should be sufficient and that it is not worth the expense and inconvenience of putting lifetime trusts in place and they almost always accept that.

However, where you have a single client they are sometimes very keen to pursue such protection. As a matter of professional conduct we are now discouraged from advising clients that such trusts will protect against care fees. I advise against and positively discourage, but I still very occasionally have clients who insist on putting a trust in place. The difficulty is that they also want your opinion on whether the trust will be effective. In England (if the guidance hasn’t changed and they meet the criteria), I think you are in Catch 22 situation: the advice has to be “yes”, the trust under the current guidance may well provide protection. But you then face professional difficulties in providing that advice. In Wales, I am helped by the Welsh legislation that, as far as I can see, no longer has any time limit on how far back the local authority can go. I have also been unable to find any guidance beyond the primary legislation and regulations on how to interpret it. So I am able to advise clients that, whilst these trusts may have been effective at one time, it is likely that they will no longer be effective in Wales.

If the English guidance remains as was, then the guidance is at fault more than the people recommending these trusts and it is not just the unregulated sector that recommends them. The guidance should be changed and it should be made clear (in Wales also) that there is no time bar on transactions to deprive. If the purpose of the transaction was to put assets beyond the reach of the local authority then there should be no capital disregard. Further, there needs to be a presumption in favour of the local authority that it is deprivation within the legislation if there is no other reasonable explanation for the transaction; wishing to avoid probate fees being deemed not to be a reasonable explanation. That would make it absolutely clear that there is no justification for recommending such trusts save perhaps where the purpose is to avoid IPFDA claims.

Will there necessarily be a TYA? Surely, it depends on what NRB is available to the trust and the value of the property?

Most customers of these trusts are not properly advised of the downsides. They are sold as an upside only magic panacea: just sign here and here.

Measures to stymie the local authority are like Russian Roulette. Guidance is not writ in stone. It can change and if not followed Judicial Review is the remedy. Good luck with that. So far as counteraction based on intention, undertaking a scheme sold on the precise basis of facilitating the insulation of one’s assets from confiscation is a lay down Grand Slam as constituting deprivation.

Putting one’s assets definitively beyond the local authority’s reach invariably means transferring them in lifetime irrevocably to someone else’s legal ownership and control.

In order not to be consigned to receive care at the grim level of the modern Workhouse at some future date you might then regret being unable to access your divested funds.

This is true even where the first spouse to die leaves their interest in their home by Will to the surviving spouse for a life interest. That half value of the house is ring-fenced but the trustees not the life tenant are in charge of whether the house should be sold and the trust’s share of the proceeds used to pay for the life tenant’s care fees, which also requires the trust to actually permit that, by a power of appointment to the life tenant.

Politicians are to blame. If the Goverment accepted the excess liability above a cap on exposure, an insurance-based market might be made for people to insure against the risk up to the cap amount. This is the classic role of insurance: risk spreading where those who never suffer calamity in the event pay to subsidise those who do, like home and motor insurance. A cap on liability is essential or some will be refused insurance: so the Government must underwrite the excess. Commercial insurers cannot make a market to cover risks which are a near certainty or which, though remote, will be disproportionate in effect, even open-ended.

Meanwhile care fee exposure is a lottery and a tragedy for those whom lightning strikes, save for the very wealthy who can afford to, in effect, self-insure.

Jack Harper

Jack, you do, of course, make valid points, but many clients are prepared to take the risk rather than see their only asset depleted almost entirely by care fees. The client should always be a trustee and the letter of wishes make it clear that their interests are paramount. The vast majority appoint their children as additional trustees and most children will want the best for their parents. There will always be exceptions, but in my experience, most parents with moderate means are prepared to take that risk. Of course, if there are concerns, then professional trustees can always be appointed.

Mark, all no doubt advised a full IHT return required on death (it’s a GRoB), loss of RNRB, HMRC registration and likely reporting requirements, including CGT PPR claims as required.

In my experience, clients who have taken the leap are rarely advised of these aspects.

I am sure Karl is right but there is a similar factor at work. Many clients, even with plenty of IQ and sound judgment, simply do not register the complexity and thus the often counter-intuitive consequences of tax concepts.

I can recall many occasions watching their eyes glaze over while I tried to explain them, with diagrams, before I had barely got started towards first base on the long journey to comprehension. The words and pictures make an entry but they are just not processed.

What a living nightmare is a GROB turbo-charged with a dose of POAT for an individual who has lived their entire life to date in the real world of common sense and cause and effect!

Part of a good adviser’s armoury and duty is to steer a client away from plans and structures which, however effective they may prove, are judged likely to be a burdensome worry in future for them and later generations. I often found a marked difference between private and business clients in the appreciation of financial risk and its management; the latter were used to that on a daily basis.

This approach is, self-evidently, the very antithesis of that of the product salesperson whose earnings are linked to signing up punters and being long gone when buyer’s remorse surfaces. One of my USPs, even as against first class large firms with staff turnover, was that clients knew I would still be around to help them with any issues later arising from arrangements they had committed to largely relying on my expertise.

A big problem with scheme merchants is that they do not have the target’s best interests as a primary objective, if at all.

Jack Harper

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I rarely put these in place Jack as when I get asked the age old question of “putting my house in a Trust”, when I explain it as I say above, they often move away from the idea, which suits me totally.

Hi Karl, the comment you are replying to was with reference to a FLIT or property trust of half of property in the will. I do not recommend life time trusts to clients, but I personally feel a FLIT in the will is, for many clients (I deal mostly with clients of moderate wealth) a good option.

And made even more complex by the introduction of RNRB. I feel it is my duty to advise then of the potential protection available via their wills and it is certainly hard work to explain the obscenely complicated IHT regime that now prevails.

My apologies Mark…I should read the whole thread….

A tenancy in common of the main residence plus an IPDI to the surviving spouse by Will of the half share of the first to die is fine and at least affords the opportunity to resist the local authority’s depredations.

To preserve RNRB on the settled share on the second death the remainder to the IPDI must be outright to persons who will “closely inherit” or on a DT whose trustees can appoint outright remainders during the IPDI holder’s lifetime; riskier as to timing as s.144 does not apply. The IPDI holder can be given a general power exercisable only by Will to appoint an IIP to follow their own which HMRC accepts is an IPDI. The donee of the power must of course ensure their Will does that! But a fixed successive IIP remainder to the IPDI does not work.

Jack Harper

No problem. We’re all guilty of that nowadays. Information overload!

Could it be argued that as the property was never actually transferred (no TR1 completed) into the names of the trustees that the trust was not constituted? There is only the restriction on the property noting the existence of the trust but no formal transfer. The trust deed defines the trust fund as as the property specified in the schedule and then the schedule lists the property but there was no actual transfer. Is the settlors signing the trust deed enough to constitute a transfer of the property?

I am trying to find the best route out of this mess for the clients but if it is to pay the TYA and then appoint out and pay exit charge then so be it.

The OP stated that the trust deed specified the trust property in the First Schedule as an identified residence. The trust would therefore be completely constituted on execution provided the Settlor then owned the equitable interest in that property or had the unequivocal right to obtain it or direct its transfer to the trustees. The effect of a valid deed is to oblige the Settlor to complete his gift notwithstanding the absence of consideration.

Where the settled asset admits of comprising an equitable and legal title, so is not a chattel or an interest in a trust, but is land or company shares the Settlor is obliged to procure the transfer of the legal title to the trustees, if he owns it or can command its transfer by a third party in whom it is vested, but if he cannot or will not that does not matter provided the equitable interest has passed.

To impugn the validity of the trust you must be able to cogently advance the subsistence of a vitiating factor. The most promising candidates are sham and mistake. Sham is unlikely to appeal to Equity’s conscience when argued by a culpable party rather than a third party with clean hands, such as a creditor or divorcing spouse or HMRC.

Mistake may have a chance, especially if the evidence supports the argument that the Settlor was misled by a nasty snake oil salesman who neither knew nor cared whether the trust was suitable to achieving the objectives claimed for it. One thing in favour is its vestigial implementation apart from execution. Another would be an entirely blameless claimant who would be entitled to the property if the trust was held void for mistake.

The bad news is that while all relevant parties, essentially trustees and beneficiaries (assuming all are ascertained and adults with capacity), could enter into a compromise agreement under seal to regard the trust as void ab initio, the Establishment is unlikely to accept that outcome without a Court order or declaration. HMRC is the most obvious immovable object, although HMLR may also be depending on who is currently registered as proprietor. HMRC might accept Counsel’s opinion.

For a professional adviser there is a risk of behaving unethically by being instrumental in assisting clients to do something underhand. Lay clients might decide to regard the trust as a dead letter and accept the risk that this might come back to bite them. That might not be intrinsically unlawful, at least not criminal, but that line might be crossed thereafter by their later denying the trust’s existence or that independent advice was taken about its validity.

On the basis that it was incipiently void there would be no undisclosed tax liabilities or omitted reporting obligations; if however it was valid there will have been a failure to report a CLT by the settlor and of the trustees to register on TRS (though any gain on disposal by the Settlor may have been exempt).

Trying to balance duty to the clients with self-preservation I would suggest to them that, if I was to be able to advise any further, I be instructed to persuade HMRC to accept the technical analysis most favourable to the clients. I cannot judge of course what the downside might be of an HMRC refusal. But the disclosure will be unprompted and could conceivably be settled cheaply on the basis that it was initially void or, if not, on payment of any tax, interest and penalties so it can be unwound if desired or retained with certainty as to the tax cost of doing either.

Jack Harper

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Thanks Jack. As always your analysis here stands out as lucid, enjoyable and authoritative.