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Principal charge meaning

What does Principal charge mean?
In UK trust practice, a principal charge is the periodic inheritance tax (IHT) charge that can arise on “relevant property” held in a trust at each ten‑year anniversary of the trust’s commencement (the ten‑year charge). It is a descriptive practitioner term (not defined in statute); the legislation (Inheritance Tax Act 1984, relevant property regime) and HMRC guidance refer to a periodic charge. Key features: - Applies to relevant property trusts (commonly discretionary and most post‑2006 trusts without an immediate post‑death interest), not to excluded categories (for example, qualifying disabled person’s trusts) and subject to exemptions/reliefs (such as spouse exemption, business or agricultural relief). - Calculated by reference to the market value of the relevant property at the anniversary, the available nil‑rate band, additions and previous charges, with a maximum effective rate of up to 6%. - Distinct from an exit charge, which may arise on distributions or when property ceases to be relevant property between anniversaries. - Trustees are liable, must file the IHT100 (and schedules) and pay within six months of the end of the month of the anniversary; interest accrues if late. Usage and effect are consistent across England & Wales, Scotland and Northern Ireland. In Ireland, there is no...
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View the related Checklists about Principal charge

CHECKLISTS
UK corporate loans: direct and indirect tax checklist for bilateral and syndicated borrowing (interest relief, CIR, transfer pricing, hybrids, withholding tax, VAT, stamp duty, SDRT, FATCA and CRS)

Checklist This Checklist sets out the principal direct and indirect tax considerations that a corporate borrower within the scope of UK corporation tax (a UK corporate borrower) ought to assess both prior to entering into a loan and over the life of that loan... It is designed to be used as a Checklist by the tax adviser to a UK corporate borrower, offering a concise outline of the relevant tax matters and providing space for the adviser to record notes... This Checklist proceeds on the basis that: the borrower is a company within the charge to UK corporation tax in relation to the loan, that is, either a UK tax resident company or a non‑UK tax resident company for which the loan is attributable to its UK permanent establishment (a UK PE), or attributable to the non‑UK resident company’s trade of dealing in or developing UK land; and the borrower and the lender are unconnected parties dealing at arm’s length ...

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CHECKLISTS
Buyer's Checklist for Acquiring Registered Freehold or Leasehold Commercial Property, Vacant Possession or Investment: Due Diligence to Post-Completion (England and Wales)

This Checklist is intended for situations where you act for the buyer acquiring a registered freehold or leasehold commercial property, whether with vacant possession or already let under one or more leases. It is not comprehensive and cannot anticipate every scenario in every deal. You should always assess if any further points require attention. It is assumed that: the property is not subject to any residential tenancies; and the seller is solvent This Checklist covers these principal areas: Preliminary matters Is the buyer using finance to acquire the property? Before exchange of contracts Are you ready to exchange? Exchange of contracts Post exchange steps Between exchange and completion Are you ready to complete? Completion Post completion Preliminary matters See also Practice Note: Transferring commercial property—a practical guide — Preliminary matters. Are the buyer’s instructions and intended use for the property clear? Strong due diligence and effective...

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CHECKLISTS
Block transfer orders for insolvency office-holders: applications, parties, evidence, court powers, notices and costs—checklist (England and Wales)

This Checklist should be read in conjunction with the Practice Note: Block transfer orders—the law and practice. Read this Checklist alongside the Practice Note: Block transfer orders—the law and practice. There are three principal scenarios that necessitate a block transfer of office-holder appointments: where an office-holder dies on the retirement of an office-holder from practice where an office-holder is otherwise unable or unwilling to continue in office. This may happen if an office-holder moves firms, or loses their licence to practise as a result of regulatory action The Insolvency (England and Wales) Rules 2016 (IR 2016), SI 2016/1024, rr 12.35–12.38, govern applications to the court for the block transfer of cases from one office-holder to another. The block transfer application process applies to the following types of appointment: compulsory liquidation (winding up by the court) voluntary liquidation (both members’ voluntary liquidations and creditors’ voluntary liquidations) administration bankruptcy voluntary arrangement (both company voluntary...

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NEWS
UK tax highlights: Court of Appeal BlackRock transfer pricing/unallowable purpose; 1.5% stamp duty capital-raising exemption; VAT consideration; remittance; MTD ITSA penalties; pensions LTA abolition (11 April 2024)

In this issue: Companies and corporation tax Stamp taxes VAT Individuals and income tax Taxes management and litigation Employment taxes Budget and Finance Bills Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax Court of Appeal decides interest on intra-group loans not restricted under transfer pricing rules but debits disallowed under unallowable purpose rule (BlackRock Holdco 5, LLC v HMRC) BlackRock Holdco 5, LLC v HMRC [2024] EWCA Civ 330 considers whether, for UK tax purposes, interest on intra‑group borrowing put in place to help fund a commercial acquisition is deductible. Two principal points were before the Court of Appeal: the transfer pricing analysis and the loan relationships unallowable purpose question. On the transfer pricing limb, the Court of Appeal allowed the taxpayer’s appeal. As a result, deductions for interest on the intra‑group loans were not curtailed by the transfer...

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NEWS
CJEU AG: misleading post-assignment use of designer surname trade marks may justify revocation; high evidential threshold and guidance for proprietors and designers (PMJC v [W] [X])

PMJC SAS v [W] [X], [M] [X], [X] Créative SAS Case C‑168/24 What are the practical implications of this case? If the Court of Justice adopts the Advocate General’s view, the principal practical effects for proprietors of patronymic trade marks and for designers are set out below: Use of patronymic trade marks Holders of patronymic trade marks matching an initial fashion designer’s name should proceed with care, ensuring their use does not mislead consumers into thinking the goods are linked to that original designer when they are not. For example: a campaign featuring the original designer could cause consumers to wrongly believe the designer took charge of the artistic supervision of the goods. This may amount to conduct justifying revocation for misleading use of the trade marks in issue marketing materials and communications should avoid statements implying the goods were designed in partnership with the initial designer where that is not so, and decorations or features which are indicative of...

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NEWS
Property law weekly briefing: planning, leasehold reform, building safety and business rates—England, Wales and Scotland (15 January 2026)

In this issue: Key developments and horizon scanning Residential property Property development Statutory compliance Transferring property Property insolvency Property taxes Property in Scotland Statutory compliance Additional property updates this week Daily and weekly news alerts New and updated content Trackers Key developments and horizon scanning Property and Property Disputes—major developments in 2025 and a comprehensive look ahead to 2026. This News Analysis brings together and summarises the principal shifts across Property and Property Disputes in England & Wales during 2025 and anticipates what is on the horizon for 2026. This edition spotlights business tenancies, the Leasehold and Freehold Reform Act 2024, residential tenancies, building safety, service charge and outgoings, commonhold, electronic communications, contractual controls on land, adverse possession, investigating title, the ‘Etridge’ protocol, energy performance and business rates. See News Analysis: Property and Property Disputes—key developments in 2025 and horizon scanning for 2026. Residential property RICS responds to government...

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PRACTICE NOTES
Service charges in Scottish commercial leases: disputes, lease interpretation, RICS Service Charge Standard, and remedies

What is a service charge? A service charge is a sum a tenant may have to pay to a landlord under a commercial lease to reimburse the landlord for services they provide in connection with the common parts and for the upkeep of the property. Commonly, this applies where multiple tenants occupy one property, for example a shopping centre, and the landlord looks after the communal parts of the building for everyone’s benefit. In most contemporary leases the tenant pays the service charge on account, before the landlord incurs the expenditure, calculated from an estimate of the next year’s costs. At the close of the accounting period a reconciliation is prepared and any shortfall or surplus is settled by or to the tenant. Sometimes, earlier forms of lease stipulate that the landlord must meet the outlay first. For more detail on service charges ordinarily charged to tenants of multi-occupied buildings by commercial landlords in Scotland, see Practice Note: Service charge and outgoing provisions in commercial leases in Scotland. ...

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PRACTICE NOTES
UK REIT tax regime: eligibility, ring-fenced property rental business, compliance tests, breaches, and taxation of REITs and investors

UK real estate investment trusts (UK REITs) The UK regime for real estate investment trusts (REITs, termed UK REITs in statute) took effect on 1 January 2007. There are now in excess of 150 REITs, several of which moved into the structure when the framework first commenced. Those early adopters have since been joined by many more participants owing to revisions to the entry criteria, in particular the following: the removal of the entry charge; permission for REITs to invest in other REITs; and a relaxation of the listing condition so that companies without a formal listing, but admitted to trading and actually traded on a recognised stock exchange (for example on markets such as AIM), can also qualify. Further amendments have been introduced to the REIT rules in recent years with the stated intention of making the regime more appealing to prospective entrants. The principal legislative provisions for the REIT tax regime sit in Part 12 of the Corporation Tax...

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PRACTICE NOTES
England: Leaseholder deed of certificate under the Building Safety Act 2022—requests, deadlines, form, execution, evidence, service and qualifying lease presumption

This ‘how to’ guide considers how to serve a leaseholder deed of certificate (LDC) under the Building Safety Act 2022 (BSA 2022) The service charge protections in Schedule 8 apply solely to ‘qualifying leases’ under BSA 2022, section 119(2) (subject to one exception). An LDC verifies whether the lease meets section 119(2)(d). This ‘how to’ guide outlines the LDC’s format and service, the supporting evidence required, and any relevant deadlines. Under section 119(2) of the BSA 2022, a lease is ‘qualifying’ only if conditions (a) to (d) are all satisfied. Conditions (a) to (c) are relatively clear: broadly, it must be a long lease (over 21 years) of a dwelling, the tenant must be liable for a service charge, and the lease must have been granted before 14 February 2022 — see Practice Note: Building Safety Act 2022—landlord and tenant issues — Remediation of historic defects—definitions. Condition (d) of section 119(2) is met if, as at 14 February 2022, the: dwelling was the relevant tenant’s (i.e....

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PRECEDENTS
SRA-compliant Fixed-Fee Price and Service Information Notice Template for Law Firms (England and Wales)

1 Legal costs 1.1 The legal costs of [ insert brief description of services, eg obtaining a grant of probate and distributing an estate ] consist of [ two OR three ] principal elements: our fees; outlays we pay on your behalf (often referred to as disbursements) [ ; OR . ] [ costs you may need to pay to another party. ] 1.2 Our charges We apply a fixed-fee structure [ of £[ insert price excluding VAT ] OR ranging between £[ insert price excluding VAT ] and £[ insert price excluding VAT ] depending on [ insert description of the factors that will dictate where in the fixed price range your fees will fall, eg the value and complexity of your matter ] ] . [ If a matter or transaction does not reach completion, we reserve the right to charge for the work undertaken, using our standard charging rate of £[ insert rate...

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PRECEDENTS
Ireland: Precedent Data Subject Access Request for Medical Records—Consent Authorising Release to Solicitor (GP, Hospital and Radiology)

For an overview of Irish data protection law and its principal concepts and rules, refer to Practice Note: Ireland—Data protection basics. Data Subject Access Request (Pursuant to the General Data Protection Regulation and Data Protection Act 2018) I am lodging a data subject access request via a third party—my solicitor (details set out below). Kindly provide my solicitor with copies of my complete medical records, in both hard copy and electronic form, inclusive of all radiology. Given these files ought to be easily located by reference to my personal data outlined below, this request is reasonable and the materials should be supplied free of charge within one month. This request is made to advance a [ civil personal injury claim ] against a third party. Appointed medical experts may rely on the records to assess my injuries and symptoms and to review any pertinent prior medical history. For the avoidance of doubt, this is a data subject access request made on my own behalf...

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PRECEDENTS
Internal Communications Plan Template for in-house Legal and Compliance Teams (Bribery Act 2010 training example)

1 Objectives Provide an overview of your principal aims here. For example: To meet the requirements of the Bribery Act 2010, we must ensure every employee completes the online training that covers our anti-bribery and corruption policies and procedures. This must be finalised by [ insert date ]. All staff should understand that they are required to have finished the online training, including the self-assessment form, by this deadline... 2 Budget Provide information on any budget you can make available for the project here. For example: We have allocated £[ insert figure ] for promotional materials. All training materials have already been commissioned and paid for. Please charge to cost code [ insert ]... 3 Audience details 3.1 Audiences involved Set out here details of all the people you need to communicate with. Depending on the size of your organisation and/or project, you may wish to arrange this by individual, by team or by division...

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Q&As
Two discretionary trusts years apart: NRB for IHT periodic/exit charges?

Practice Note: Relevant property trusts—the principal (ten-year) charge within the Trusts—inheritance tax subtopic For details on the inheritance tax (IHT) rules applicable to discretionary trusts under the relevant property regime, see Practice Note: Relevant property trusts—the principal (ten-year) charge within the Trusts—inheritance tax subtopic...

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Q&As
NRB trust IHT 10-year charge: RPI-linked debt; excepted settlement

How should the trustees report the amount of the debt for the purposes of IHT ten-year charge? Should they include any index-linked element of the debt? We have found no authority directly answering this. The principal, or ten‑year, charge is imposed on the value of relevant property held by the trustees immediately before the ten‑year anniversary (TYA). See Practice Note: Relevant property trusts—the principal (ten‑year) charge. Where the trustees’ asset is encumbered by a charge with an index‑linked feature, the trust fund must be valued correctly just before the TYA. That exercise turns on the precise balance outstanding at that point and on whether the index‑linkage ought to be reflected, notwithstanding it would only bite once the loan is redeemed. As a broad rule, where property is charged, the amount secured is deductible from the property’s value when computing the IHT charge (section 5(3) and sections 162–166 of the Inheritance Tax Act 1984 (IHTA 1984)). There are, however, limited departures from that general position. Consequently, the amount to be...

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