Barclays Wealth Trustees (Jersey) Ltd and another v Revenue and Customs Commissioners [2015] EWHC 2878 (Ch), [2015] All ER (D) 89 (Nov)
The Chancery Division dismissed the appellant taxpayers’ appeal against a determination of a liability for inheritance tax said to have arisen in relation to the 10-year charge applicable to trusts. It held that, on the correct interpretation of the Inheritance Act 1984, the property in question was not “excluded property” and so the 10-year charge applicable to trusts would apply.