Inheritance Tax Act 1984 section 90

Trustees' annuities, etc.

Section 90 provides an inheritance tax exemption for interests in possession held by trustees as remuneration for their services, provided the interest does not exceed a reasonable level of remuneration.

• Where a trustee holds an interest in possession in settled property as remuneration for acting as trustee, special inheritance tax treatment applies.
• Provided the interest does not exceed a reasonable amount of remuneration, it is excluded from the value of the trustee's estate immediately before death.
• No inheritance tax charge arises under section 52 when the trustee's interest in possession comes to an end, again provided it does not exceed reasonable remuneration.
• If the interest does exceed what is considered reasonable remuneration, the excess will be subject to the normal inheritance tax rules for interests in possession.