Nader (as Executor of Estate of Dickins, deceased) and others v Revenue and Customs Commissioners

Inheritance tax – Exemptions and relief. The proceedings concerned an inheritance tax avoidance scheme implemented by the testator which involved the testator borrowing money to buy a life income interest in an offshore trust. The appellant beneficiaries under the testator's will subsequently appealed against the notices of determination issued by the Revenue and Customs Commissioners under the Inheritance Tax Act 1984. The First-tier Tribunal (Tax Chamber) dismissed the appellants' appeal on the grounds that D's purchase of that income interest amounted to a 'transfer of value' for the purposes of s 3 of that Act, and that pursuant to s 10 of that Act, the transactions at issue were not exempted from IHT.

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