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First-tier Tribunal (Tax): Corporate settlors have a 'life' for IHTA 1984 ten-year periodic trust charges – Lexgreen Services Ltd v HMRC

Published on: 29 August 2025

Published by a Law360 reporter
Legal News
Article summary

Lexgreen Services Ltd

Acting as settlor for a connected trust, Lexgreen Services Ltd has been found liable for over £155,000 in inheritance tax, plus interest, on the £6.5m accumulated in the trust since its creation in 2005, the First-tier Tribunal decided on 21 August 2025.

In confirming HM Revenue & Customs (HMRC) 2015 assessment on the trust’s ten-year anniversary, the tribunal rejected Lexgreen’s argument that only human settlors owe inheritance tax.

Lexgreen maintained that corporations are excluded from statute, the Inheritance Tax Act 1984, which includes a charge arising on a trust’s ten-year anniversary, on the trust’s decennial anniversary under the Act...

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