Timing of 10 Year Charges

I’m looking for some books or guidance on the general question of when events in the life of a trust do, or do not, affect the timing of its ten year charge - particularly those situations where a trust might be treated for IHT as if it were two separate trusts with different ten year charge dates - in situations such as:

  • The original settlor makes a further settlement onto the trust;
  • A different settlor makes a settlement onto the trust;
  • Another trust appoints some or all of its assets onto the trust;
  • A testator makes a gift on death to the existing trust;
  • An IPDI (or pre-2006 interest in possession, or a TSI, or a s89 trust) ceases, causing assets to become comprised in the trust; or
  • Any other situation where the question arises (or might be thought to arise but doesn’t).

I stress that I’m looking for some articles or sources that discuss this generally - not necessarily answers to these questions.


Tolley’s Taxwise Volume II provides worked examples and explanatory notes. This is an annual publication and is usually updated round about now - so for 2023/24.

Gill that’s brilliant, thank you.