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KEY POINTS
- The Coulter Trust was established in Jersey to build care homes for older people.
- HMRC said the executors were not entitled to relief under IHTA 1984 s 23.
- Did the restriction breach the EU freedom of movement of capital?
- Court of Appeal concluded s 23 applied to trusts established under UK law.
Beryl Coulter died in Jersey on 9 October 2007. She left her residuary estate in the UK on trust for the purpose of building residential care homes for the bailiwick’s older people. There was a gift over in favour of Jersey Hospice Care. Importantly the Coulter Trust was established under Jersey law and subject to it.
HMRC determined that the executors were liable to pay inheritance tax on the residuary gift to the trust and were not entitled to...
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