The UK Revenue, HMRC, published another consultation on UK inheritance tax (IHT) changes in relevant property trusts. HMRC proposes new rules whereby each settlor is entitled to a 'settlement' nil rate band ('SNRB') separate from the personal nil rate band but where the SNRB will need to be allocated by the settlor between any other settlements created by that settlor so as to avoid the fragmentation of ownership of property across a number of settlements to avail of exemptions and reliefs. The changes will apply to any settlements created or added to after 6 June 2014.
