A trust owns all of the share capital of a limited company worth say £10 million
The company issues shares to acquire the business of another company. The trust thereafter owns 66% of a group worth say £15 million.
Is there an exit charge under s65(1b) IHTA 1984 owing to the value of the shareholding after the transaction needing to be discounted for the loss of overall control?
Second scenario. The trustees of a trust comprising discretionary property grant its beneficiaries interests in possession.
Is there an exit charge under s65(1b) IHTA 1984 owing to the capitalised value of trust assets being reduced on account of the trustees lack of income stream?
EDITED from s65(2) to s65(1b) at 9-16am 1st March - sorry for the error: DoG