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If an employee benefit trust or sub-trust (IHTM42970) was set up before 6 April 2006, you may need to determine whether it is a sponsored superannuation scheme (IHTM17039) before you can establish whether any tax charges arise on the trust.

Before 6 April 2006, a sponsored superannuation scheme fell within IHTA84/S151 and was excluded from being a relevant property trust by the provision in IHTA84/S58(d). Although this category of pension scheme was removed from the relevant Inheritance Tax exclusions with effect from 6 April 2006 there are transitional provisions for schemes that were in existence at that time. »Ê¹ÚÌåÓýappse provisions allow for a scheme that was within IHTA84/S151 immediately before 6 April 2006 to continue to be excluded from being relevant property, but only where no further contributions were made under the scheme on or after that date.

»Ê¹ÚÌåÓýappre are apportionment provisions if further contributions are made on or after 6 April 2006 but you are unlikely to see cases where the scheme trustees are not excluded from an Inheritance Tax charge. If you do come across a case where contributions have been made after 6 April 2006, you should refer it to Technical.