Inheritance Tax Act 1984 section 271

Property of corporations sole

Section 271 excludes property held by a corporation sole from being treated as property to which a person is beneficially entitled for inheritance tax purposes, with one exception.

• A corporation sole is a legal entity consisting of a single office holder, such as a bishop or the Crown, whose property passes with the office rather than personally.
• Where a person holds property in their capacity as a corporation sole, that property is not treated as property to which they are beneficially entitled for inheritance tax purposes.
• This exclusion applies throughout the Inheritance Tax Act 1984, meaning that property held by a corporation sole generally falls outside the scope of inheritance tax charges that depend on beneficial entitlement.
• The sole exception is section 59, which deals with qualifying interests in possession in settled property — in that context, property held as a corporation sole can still be regarded as beneficially owned.