Having your cake and eating it: Interest and Tax free loans after Varying a will

Chris advised the clients to put a portion of their £10 million inheritance from their late mother into Trust to potentially reduce the Inheritance Tax liability and ring-fence the assets.

Chris effected a Deed of Variation to make this possible and advised the clients on HMRC’s recent change of view of speciality debts which allows the clients to borrow money from the Trust interest free without consequent tax arising on the loan when they die.

The loan would be a debt on the estate so, whilst this would need to be repaid, the clients can enjoy their inheritance with the peace of mind that their inheritance is ring-fenced from their estate.