IHTM42977 - Employee benefit trusts: sub-trusts: company as settlor
The issues that are relevant where contributions are made to an employee benefit trusts (EBT) by a 听肠辞尘辫补苍测听are outlined at鈥�IHTM42953.听
However, once the assets are settled into trust, the trust itself will be subject to:听
all the conditions outlined in this chapter, and听
Inheritance Tax in the same way as any other trust or EBT once it is established.听
Where the sub-trusts are relevant property trusts, all the normal issues concerned with the trust charges, long-term UK residence (IHTM47000) (on or after 6 April 2025) or domicile (IHTM13000)听of settlor听(before 6 April 2025)听and location of assets will need to be considered. In many cases, the sub-trust funds will have been loaned to the beneficiaries, so even if the company settlor and the trustees are overseas, if the beneficiary is resident in the UK, the debt owed to the trust will be a UK asset and potentially subject to both the ten-year and exit charges (IHTM42975).听