Lexgreen Services Ltd v Revenue and Customs (INHERITANCE TAX - Meaning of life - s 201(1)(d) IHTA - does section apply to a corporate settlor? - was transfer made 'during the life of the settlor'?) [2025] UKFTT 1019 (TC) (21 August 2025)

Lexgreen Services Ltd v Revenue and Customs (INHERITANCE TAX - Meaning of life - s 201(1)(d) IHTA - does section apply to a corporate settlor? - was transfer made 'during the life of the settlor'?) [2025] UKFTT 1019 (TC) (21 August 2025)

A company can be liable for inheritance tax under s 201(1)(d) IHTA 1984 as a settlor if it is a live company at the time of the relevant transfer. The phrase 'during the life of the settlor' can be interpreted to mean the period during which the company exists. The Appellant was a live company at all material times, so the transfer was made during its life and it is liable for the tax charge.

Citation
[2025] UKFTT 1019
Parties
Appellant: Lexgreen Services Limited; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
21 August 2025
Procedural Posture
Tax Appeal / First Tier Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
Inheritance Tax, Statutory Interpretation, Corporate Settlor Liability
Tax Law Inheritance Tax Statutory Interpretation Corporate Settlor Liability

Case Brief

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Parties

Lexgreen Services Limited

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Judgment

Legal Issues

  1. 1 Whether a company can be liable for inheritance tax under s 201(1)(d) IHTA 1984 as a settlor
  2. 2 Whether the transfer was made 'during the life of the settlor' where the settlor is a company

Ratio Decidendi

A company can be liable for inheritance tax under s 201(1)(d) IHTA 1984 as a settlor if it is a live company at the time of the relevant transfer. The phrase 'during the life of the settlor' can be interpreted to mean the period during which the company exists. The Appellant was a live company at all material times, so the transfer was made during its life and it is liable for the tax charge.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.