Katya Vagner
Katya Vagner (Ekaterina Vagner) is an associate in the Private Client department at Fladgate.
She specialises in advising on a wide range of UK and offshore private client legal and tax matters.
Katya advises individuals and business owners, their families, family offices, trustees, personal representatives and charities across the globe on issues such as estate and succession planning (including Wills and inheritance tax advice), setting up and advising on onshore and offshore structures (such as trusts and foundations), incapacity planning (including Lasting Powers of Attorney and Court of Protection matters), administration of trusts and estates and issues involving charities (such as advising on charitable giving and advising charities on a range of legal and tax issues).
Katya has a keen interest in ESG initiatives and has a growing charities and philanthropy practice, advising on structuring of UK and cross-border charitable giving and administering charities.
Recognised as one of the 2019 eprivateclient Top 35 Under 35 advisers, Katya is a native Russian speaker and is a full member of the Society of Trust and Estate Practitioners (STEP), the Law Society Private Client Section and the Charity Law Association. Katya has written for industry publications including the Tax Journal, CityWealth Magazine and the Journal of International Tax, Trust and Corporate Planning.
Practice Area
Panel
- Contributing Author
3 Contributions by Katya Vagner
PRACTICE NOTES
Quick Succession Relief in UK Inheritance Tax: five-year scope, calculations, examples, interaction with 36% charitable rate and legacies, settled property, claim process, and recent reforms
Quick succession relief (QSR), not to be mistaken for taper relief, applies where a transfer of value is subjected to a further inheritance tax (IHT) charge within five years of the original gift or chargeable transfer. Consider a case where someone receives a lifetime gift (or inherits on a death) in year one, with IHT settled at that time, and in year three that recipient dies still owning the asset so it falls into their taxable estate and IHT is again due. QSR provides relief against this second IHT bill, calculated by reference to the IHT paid on the earlier transfer and the interval between the two events.
How the relief works and when it applies
Relief for successive charges, also called QSR, is available when the value of a person’s estate has been increased by a chargeable transfer—whether made during life or on death—occurring not more than five years before their death. The IHT arising on death is reduced by a percentage of the IHT charged on the net amount that the deceased received from the first transfer. The definition of...
Private Client
PRACTICE NOTES
UK IHT: 36% reduced rate for 10%+ charitable giving—component-based calculations, merger elections, relief interactions (RNRB, APR/BPR, GROB), will drafting and post-death variations
STOP PRESS :
Further to the Autumn Budget 2024 announcement on 30 October 2024, the 100% relief for APR and BPR on qualifying property will be curtailed by a combined allowance of £2.5m with effect from 6 April 2026. Refer to section 65 and Schedule 12 of the Finance Act 2026, which amend sections 104 and 116 onwards of the Inheritance Tax Act 1984. See also Practice Notes: IHT—agricultural property relief and IHT—business property relief.
On death, an individual is regarded as having made a transfer of value equal to the value of their estate immediately before death.
Exemptions from UK inheritance tax fall into three categories:
those applying only during lifetime
those available either during lifetime or on death
those applying solely on death
Most IHT exemptions can apply to both lifetime dispositions and transfers on death, including the exemption for charitable gifts. As a rule, transfers to a qualifying UK charity or a registered amateur sports club in the UK are exempt from IHT. The charity exemption is widely relied upon and, in practice, the personal representatives (PRs) will usually only need to provide the registered charity...
Private Client
PRACTICE NOTES
UK IHT: Discretionary Will Trusts, s.144 Two-year Relief, Relevant Property Charges, NRB/RNRB Planning, Drafting Considerations, CGT/SDLT Points, and Comparison with s.142 Variations
A discretionary trust provides a highly adaptable type of arrangement. Under such trusts, trustees exercise discretion over when distributions are made, in what manner, and to which recipients, covering both capital and income. Beneficiaries, or a class of them, appear in the trust deed, and the choice of who among the potential beneficiaries should benefit rests wholly with the trustees, sometimes with the guidance of a letter of wishes. Accordingly, timing, method and recipient of any payments are decided case by case.
Why discretionary Will trusts are used
There are times when passing assets straight to a beneficiary under a Will is not advisable. For instance:
the beneficiary is, or in the future might become, bankrupt
the beneficiary is, or in the future might be, going through divorce
the beneficiary is disabled, needs help with managing money, or receives state benefits, where any money received directly from the estate might affect their entitlement to such benefits
prospective beneficiary is very young at the date of the making of the Will and it is not prudent to make any assumptions about their future family/financial circumstances
to allow the easiest account to be taken of lifetime gifts to achieve equalisation between various...
Private Client
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