The Upper Tribunal has handed down judgment in Lexgreen Services Ltd v HMRC [2026] UKUT 289 (TCC). The case concerned whether a corporate settlor could be liable for inheritance tax on settled property held by non-resident trustees, in circumstances where the trustees had failed to pay the tax. The appellant company argued that it was not liable because (among other things) section 201 of the Inheritance Tax Act 1984 provides that a settlor is only liable during “the life of the settlor”. The appellant contended that it did not have a life because it was a company, and so the provision did not apply. This argument was rejected: the meaning of “life”, in this context, includes the period for which a company is in existence.
The judgment is also notable for a reference to The Hitchhiker’s Guide to the Galaxy in footnote 3.
James Kirby appeared for HMRC, the successful respondents to the appeal.
The Tribunal’s decision may be found here.
