Accuro Trust (Switzerland) SA v HMRC

In Accuro Trust (Switzerland) SA v HMRC [2025] UKFTT 464 (TC) (28 April) the First-tier Tribunal (FTT) held that foreign property added to an excluded property trust in March 2006 when the settlor had become deemed domiciled in the UK was excluded property and that IHT paid based on the mistaken belief that it was due should be repaid. The natural meaning of the words meant that the additions were not relevant property and that HMRC’s view was not ‘generally received or adopted in practice’.

The settlor established a trust in Switzerland in September 1992 when he was neither domiciled nor deemed domiciled in the UK. Various funds were added to the trust by the settlor up to 6 April 2005 when he became deemed domiciled in the UK. The settlor then added a substantial amount...