IHTM42989 - Employee benefit trusts: property leaving employee benefit trusts: definitions
IHTA84/S72(6) gives definitions of 바카라 사이트˜close company바카라 사이트™, 바카라 사이트˜participator바카라 사이트™ and 바카라 사이트˜year바카라 사이트™ and incorporates the same anti-avoidance provision as in IHTA84/S53(6) in relation to acquisition for consideration.
S53(6) directs that
바카라 사이트˜a person shall be treated as acquiring an interest for consideration in money or money바카라 사이트™s worth if he becomes entitled to it as a result of transactions which include a disposition for such consideration (whether to him or another) or that interest or of other property바카라 사이트™.
The subsection is designed to counter most sophisticated devices by which a settlor or their spouse or civil partner could in effect acquire the reversion for consideration. For example the purchaser might be a company in which the settlor held all the shares, or the trustees of a settlement in which they had an interest in possession. Alternatively, the reversioner might give the reversion to a company in which they held all the shares and the settlor might buy the shares and wind-up the company.