If you have ever wondered this First Tier Tribunal ruling is for you.
In Lexgreen Services v HMRC (2025 UKFTT 1019 TC) the corporate settlor of settled property attempted to avoid paying tax on a chargeable transfer, arguing that the charge is only payable if the transfer is made during the life of the settlor and a corporate entity does not have a ‘life’.
HMRC argued that the word ‘life’ in s.201(1)(d) Inheritance Tax Act 1984 does apply to companies, and the tribunal judge agreed that the company was a live company. The judge therefore dismissed Lexgreen’s appeal.
https://www.bailii.org/uk/cases/UKFTT/TC/2025/TC09618.html
Stephen Parnham
