Section 75B — Inheritance Tax Act 1984: Cap on charges for pre-30 October 2024 excluded property

Cap on charges for pre-30 October 2024 excluded property 75B 1 This section applies if (ignoring this section) tax is charged under section 64 (ten-year anniversary charge) or 65 (exit charge) by reference to the value of property—

a that became comprised in the settlement in question before 30 October 2024, b that immediately before 30 October 2024 was excluded property by virtue of section 48(3) or (3A) (as it had effect at that time),

and c that immediately before the occasion of the charge—

i is situated outside the United Kingdom and is not property to which paragraph 2 or 3 of Schedule A1 applies, or ii is a holding in an authorised unit trust or a share in an open-ended investment company.

2 The amount of tax charged by reference to the value of the property is, if it would otherwise be greater, to be reduced (but not below zero) to the difference between—

a the applicable cap in relation to the relevant period in which the occasion of the charge falls, and b any amount of tax already charged under section 65 in relation to the settlement, earlier in that relevant period, by reference to the value of property meeting the conditions in subsection (1).

3 In this section— “ the applicable cap ” means—

in relation to the first relevant period, £125,000 multiplied by the number of whole successive quarters in the period; in relation to a subsequent relevant period, £5 million; “ relevant period ” means— the period beginning with 6 April 2025 and ending with the first ten-year anniversary falling after that date, and each subsequent period of ten years.