Viscount Hood (executor of the estate of Diana, Lady Hood deceased) v Revenue and Customs Commissioners

Inheritance tax – Lifetime transfer. The covenants in a reversionary sub-lease to observe and perform the provisions of the head lease had amounted to a benefit by contract to the appellant tax payer within the meaning of FA 1986 s 102(1)(b). Accordingly, the Court of Appeal, Civil Division, dismissed the tax payer's appeal against the decision of the Upper Tribunal (Tax and Chancery Chamber), which had held that a reversionary sub-lease granted on favourable terms by the deceased to her three sons was subject to inheritance tax.

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