Inheritance Tax Act 1984 section 81A

Reversionary interests in relevant property

Section 81A prevents certain reversionary interests in trust property from escaping an inheritance tax charge when the reversioner becomes entitled to the trust property, and ensures that any resulting transfer of value is immediately chargeable.

• A "relevant reversioner" is someone who bought a reversionary interest for money or money's worth, or who is the settlor, or the settlor's spouse or civil partner.
• When a relevant reversioner's reversionary interest ends because they become entitled to an interest in possession in the trust property, they are treated as having made a disposition of that reversionary interest at that point.
• Any transfer of value arising from a relevant reversioner's reversionary interest is immediately chargeable to inheritance tax — it cannot qualify as a potentially exempt transfer.
• These rules apply where the relevant reversioner becomes beneficially entitled on or after 9 December 2009.