AAT RESPONSE TO THE HMRC CONSULTATION ON INHERITANCE TAX: A FAIRER WAY OF CALCULATING TRUST CHARGES

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1 AAT RESPONSE TO THE HMRC CONSULTATION ON INHERITANCE TAX: A FAIRER WAY OF CALCULATING TRUST CHARGES 1 INTRODUCTION 1.1 The Association of Accounting Technicians (AAT) is pleased to comment on the proposals set out in this further HMRC consultation document (condoc) in respect of Inheritance Tax: A fairer way of calculating trust charges which has been issued in the wake of the submission of responses to the 2013 condoc Inheritance tax simplifying charges on trusts. 1.2 AAT considers this opportunity for further consultation can only help benefit the legislative process and the quality of the ultimate outcome bearing in mind the well tested and long established practices these proposals are set to replace if enacted. 2 VESTED INTERESTS 2.1 AAT is responding to this consultation from the wider public benefit perspective of achieving sound and effective administration of taxes. 2.2 The issues raised in this condoc, if enacted, will affect: Members in Practice and their clients our employed members and the organisations that they work for settlors beneficiaries 3 GENERAL COMMENTS 3.1 Prior to responding to the condoc s questions we would like to set out our thoughts and observations in respect of the proposals contained within the condoc and the anticipated impact we believe these changes will have should they be implemented in their current form. We shall then turn our attention to the specific questions raised for further comments. 3.2 We note that HMRC proposes, in para 2.38 of the condoc, to enact the changes proposed in the Finance Bill 2015 effective from 7 June 2014 to all trusts under anti-forestalling provisions contained in the condoc. 3.3 We consider it to be unlikely for AAT to be a lone voice in objecting to the fact that 6 June 2014 has already been set as the date for the proposals to come into force on the grounds that the condoc invites comments from all interested stakeholders up to 29 August 2014.

2 3.4 The December 2013 summary of responses document 1 issued by HMRC under chapter 1 paragraph 1.10 (P4) stated proposals to Consult further on alternative proposals to split the nil-rate band (NRB) that will meet trustees concerns whilst maintaining tax revenues; and as a result Put the simplification of the calculations on a slightly lower track so that any new legislation is introduced in Finance Bill AAT acknowledges the need for HMRC to protect revenue yields from abuse and that one way to achieve this, in certain instances, is to introduce a cut-off date, from which point legislation can be backdated. 3.6 In this instance we think the cut-off to be unnecessary the measures that the anti-forestalling provisions are seeking to address are not abusive. They are in fact lawful custom-and-practice. 3.7 Instead we would like to see an implementation date which is linked within the Finance Bill 2015 or, at the very least, the time of the 2014 Autumn Statement. 3.8 The establishment of any basic trust structure requires an appropriate period of consultation to enable interested parties to input into the design of any new legislation deemed to be necessary. 3.9 In addition we would suggest that the anti-forestalling provisions should be deferred, to ensure tax practitioners are able to advise clients professionally and in possession of full knowledge of the proposed changes AAT welcomes the consideration HMRC has given to responses received from all interested stakeholders to the last consultation (1.1) (above) and the alternative model put forward in respect of applying Nil Rate Band (NRB) for trusts post 6 June We are concerned that there will be an asymmetry between the rules for an individual s Inheritance Tax (IHT) NRB, which is renewable every seven years, and the proposed new rule for the Settlement Nil Rate Band (SNRB), relevant to calculating both the ten year anniversary and exit charges, which under these proposals would not be renewable and treated as a single life-time allowance Para 1.9 of chapter 1 of the condoc (page 5) states "...we believe that it is right that there should be one nil-rate band available for those individuals settling property into trust 1 Inheritance Tax: Simplification of trust charges the next stage - Summary of Responses

3 just as there is only one nil-rate band available to an individual transferring assets on death." 3.13 We do not consider that the extract, as set in (above) forms the basis of a compelling argument. In that, it seeks to draw a comparison between a living person who has the ability to, broadly, make use of a fresh NRB every seven years and a deceased person who uses their NRB once and for all time Taking our 3.13 observation into account AAT fails to understand how it can be inherently fairer for the proposed SNRB to be available only once to a trust. Rather than renewed every seven years in the same way as the individual s NRB. We recommend that further consideration to be given to this important point AAT is disappointed that reforms originally billed as a simplification, on closer examination will undoubtedly lead to yet more complexity and potential uncertainty than the existing rules they are set to replace We are pleased, for practical reasons that it is not proposed for the SNRB to apply to pre 7 June 2014 trusts. The cliff-edge approach will alleviate issues the proposed reforms would have otherwise had for a significant number of smaller trusts should they not have been able to retain a full NRB entitlement However, AAT objects to the potential retrospection of the measures, if they were to be introduced. In particular we are concerned about the impact they would have on a significant number of existing trusts, for their future management and ultimate intended purpose as set out for them by the settler in the trust deed AAT can see a distinct disadvantage now being placed upon these trusts should these proposals proceed without further amendment. An example of this being for existing trusts to which funds are added or a trust amended after 6 June 2014 since from these actions they will then become subject to two different IHT regimes In their current form these measures will introduce an anomaly for existing pre 7 June 2014 trusts who may have a full NRB entitlement available under the old rules but would never be able to fully utilise it as originally intended, due to the nature and type of funds to be introduced to the trust. Any additions of property/funds to an existing trust made after 6 June 2014 would now need to be allocated a portion of the SNRB on or after 6 April 2015 by the settlor or have confirmation passed to them by the personal representatives of a deceased (settlor) For trustees this will increase their ongoing administration and compliance requirements together with impacting on the very purpose for the establishment of these accepted trust planning arrangements in the first instance.

4 3.21 AAT s view is that this can hardly be described as fair or a clear demonstration of simplification for the need to change the existing law for trustees dealing with trusts established on or before 7 June The introduction of a simplified flat rate charge of 6%, as proposed, for all trusts may well mean less time will need to be spent on complicated tax computations potentially resulting in a reduced level of professional fees being charged to trustees AAT can also see instances affecting a number of existing smaller trusts, whereby, they will now have to pay substantially more in tax and fees under this new regime. If this transpires to be the situation we are concerned that it would seem to go against the Government s objectives set for this consultation of delivering fairness We maintain our pre-existing view in respect of the flat rate charge of 6% that it would be fairer and simpler should the proposed changes be introduced for these to apply to new trusts only 3. With the option for existing trusts to enter the new simplified regime or remain within the current relevant property regime by election, rather than applying to all trusts under the relevant property trust regime as currently proposed Furthermore, we would add that the example set out in para 2.30 (condoc), where a couple in their 40s transfer assets equal to their NRBs into trust every seven years, is standard IHT planning which until now would not be subject to any ongoing IHT periodic and exit charges AAT does not consider this to be a typical example of the widespread methods used to fund the majority of trusts established over such a time period While we accept it to be possible for property settled into trust to be left undistributed for up to a period of 125 years we believe the likelihood of this to be extremely remote. We would only expect this to occur in a very small number of larger size trusts, with the vast majority of smaller value trusts running for much shorter time periods AAT considers that the release by HMRC of further data on this would help clarify and validate this position. 2 Para 2 of Inheritance Tax: Simplifying Charges on Trusts the next stage 3 Para 3.16 of AAT Response to Inheritance Tax: Simplifying charges on trusts - the next stage

5 4 INHERITANCE TAX: A FAIRER WAY OF CALCULATING TRUST CHARGES Questions on the simplification of IHT trust charges Q1: Are there any other provisions that would need to be made for when a settlor dies that have not been covered in this section? 4.1 AAT considers the proposals in their present form will have a varying degree of impact on a number of existing trust settlements. In particular the proposals will impact on settlements established to receive pension death benefits and trusts holding life assurance policies. Pension scheme death benefits are typically held on trust or under a deed poll based scheme. 4.2 As an example: some contract based personal pension schemes and stakeholder pensions hold benefits on trust whereas others may use a deed poll structure. In cases where pension death benefits are held in trust by the pension scheme trustees and the nominated settlement for these benefits was set up before the 7 June 2014 and pension scheme membership was established before the 7 June 2014 by the settlor. The proposed anti-forestalling provisions will not have an adverse impact on such arrangements resulting from any death benefit payments made from a pension scheme trusts structure and transferred to another trust settlement. 4.3 The condoc confirms the position that where funds are transferred from one trust to another they continue to be held under the terms of the original trust (s81 IHTA 1984) para 3.20 (condoc). Therefore, the transfer of death benefits from a pension scheme trust to another trust within the above timeline 4.2 (above) will not be treated as an addition of funds for the receiving trust. 4.4 However for cases where pension death benefits are held under a deed poll structure the payment of death benefits to a trust settlement established on or before the 6 June 2014 would, under the proposals contained under the condoc, need to be treated as an addition to an existing settlement. 4.5 Trustees would in the future be required to seek professional advice in 4.1respect of the above and verify the basis used for the method of securing such pension death benefits. AAT views this as an unintended oversight in the drafting of these proposals as this would now create the strange position of a trust having access to a NRB and no ability to use it. 4.6 AAT therefore suggests that for such deed poll based cases a provision should be added in respect of death benefits held in this way under a pension scheme for these payments, if made to a pre 7 June trust, to be not treated as an addition under the current proposals by

6 way of an exemption and to continue to be treated as a trust addition under the old provisions. 4.7 For the calculation of IHT charges in the condoc it is unclear what exactly is meant by the terms of a trust being amended as limited information has been provided by HMRC. For example would this apply to a change in trusts on which assets are held that result from a deed of variation or trustees exercising their power of appointment? We assume the SNRB will apply only to the relevant property that comes in to being as a result of the amendment, which would need to be accounted for separately by the trustees in the same way as added assets to the trust. 4.8 For simple life assurance protection trusts established prior to the 7 June 2014 such protection policies would normally have no surrender value for IHT purposes as pure protection (term assurance) polices and so only have a real value on death of the life assured (settlor). However it is not uncommon for the level of cover provided to be increased due to changing family circumstances over the life of the trust. 4.9 Following changes introduced in the FA 2006 (FA06) life contract policies already settled in trust were allowed special relieving transitional provisions.s.49e IHTA These measures protect the status of pre-budget 2006 trusts and so not bringing them in to the relevant property regime. It is AAT s view that a similar measure will need to be considered again as a change in practice is proposed in order that an existing trust is not now tainted and needlessly introduced to the new SNRB regime through the continuation of premium payments and any increases in life cover required in the future The amended provisions would need to allow for premiums to continue to be paid on existing life contracts after the 6 June 2014 together with allowing for these contracts to be varied, provided the variation is allowed under the terms of the pre 7 June 2014 life policy contract AAT considers that such payments should be treated as enhancements of value already in the settlement and should not constitute additions to the trust in line with the position HMRC has previously confirmed for the payment of life policies written in trust following FA06 changes For these reasons we would not wish to see, as a result of these proposals going forward from the 7 June 2014, the provision of family income and protection polices settled under trust being further complicated by virtue of the provisions for additions to existing trusts post 7 June 2014 having to be treated as a separate fund and so requiring a settlor election for the allocation of the SNRB.

7 4.13 AAT considers that further clarification is required We presume, following the death of the settlor as set out in para 3.13 (condoc), the position would equally apply as per for variations to a Will in respect of settlements created by a deed of variation and subject to the type of settlement created that this would now require the personal representatives of the deceased to provide the trustees with an election for the allocation of the unused SNRB should this be available to them. This election would then need to be completed within the period of two years from date of death of the testator. Q2: Are there any other features of the existing trust rules that should be retained under the new rules? 4.15 We question if the proposals in their current form justify the disruption and additional expenses to be borne by taxpayers for what HMRC have stated to be a tax neutral outcome It is widely accepted that the existing rules are well drafted and provide comprehensive coverage of almost all situations and therefore AAT considers it appropriate to preserve the full extent and value of these where possible AAT is not in favour of the introduction of piecemeal changes that, as proposed, will largely impact on existing trusts and the future use of trusts. This was the case when considering recent experiences in dealing with the last set of notable changes introduced in the Finance Act 2006 (FA06) which introduced a number of smaller trusts to the relevant property regime only for this to be repeated again introducing further compliance requirements and increased expenses for trustees AAT therefore suggests that similar special provisions as introduced for dealing with issues created by the Finance Act 2006 (FA06) for trust additions are likely to be required in order to protect existing trusts established on or before 6 June These will be required in particular to deal with the treatment of life assurance policies and the payment of pension scheme death benefits paid under a deed poll structure with further provisions for dealing with trust changes. Q3: Are there any aspects of the proposed new rules for allocating the SNRB or calculating the IHT charges that could be improved? 4.19 We note under para 3.1 (condoc) that no provision has been made for the situation that might be faced should the settlor lose mental capacity to complete this election.

8 4.20 In the absence of pre-existing provisions for dealing with the individuals financial affairs, the trustee of a settlement would have no other alternative than to complete their calculations based on none of the SNRB being available. Taking into account such circumstances it is AAT s recommendation that a special election, as an option for trustees, is introduced It is our recommendation that a revision period of, say 2 years from the date of payment, be introduced to allow for refund claims to be made in respect of IHT payments overpaid in instances where an unused entitlement to a SNRB allowance has been discovered by the trustees While we welcome the proposed approach outlined by HMRC in respect of the possible introduction of a SNRB, as we have stated at (above), we are of the view that for this to be introduced as a single life-time allowance for all trusts is unfair when it is compared and contrasted to the fact that NRB can be refreshed every 7 years AAT therefore recommends as stated at 3.14 (above) that further consideration should be given for this allowance to be refreshed in line, or in principle, with the availability of allowances/exemptions available to all taxpayers. One such consideration being the introduction of a realistic settlement life-time allowance based on a multiple of the NRB similar in principle to that used for pension schemes Shifting the emphasis to lifetime gifting and Will planning could have a number of implications for families of moderate wealth needs in the future For existing trusts, we do not necessarily see that the introduction of a standard rate charge of 6% under the simplified method of calculation proposals is fair for a large number of smaller settlements While a flat rate charge might be simpler, under the current periodic charge rules 6% is the ceiling that might be charged every 10 years and not the floor. We recommend that further consideration be given to the suggestion that we made in our 2013 response document that a flat rate of 4% should be applied. We consider that such a rate would be more acceptable to all parties As the proposals for a single rate of 6% tax under the simplification process are intended to be revenue-neutral whatever rate that is ultimately set must therefore not be seen to increase the IHT tax yield to the Exchequer From a point of view of fairness AAT recommends that, for existing trusts, the option should be provided by way of a trustee election to either deploy the new simplified calculation method or to maintain the existing method of calculation.

9 4.29 From our review of the condoc we were unable to establish whether a settlor would be able, during his lifetime, to allocate a percentage of his SNRB to a settlement included in his Will as the trust destined to be the subject of the SNRB amount will not come into existence until his death We believe that greater clarity is required over for such cases and would conclude that only the personal representatives would be able to deal with this election. Assuming this is the case, guidance on this will need to be left in a letter of wishes by the settlor covering the possibility that some of the SNRB may remain unallocated on death for allocation by the personal representatives AAT considers that the proposals for dealing with the election of the SNRB by the settlor will unnecessarily complicate arrangements for taxpayers looking to establish new trusts post 6 June Our concern can be illustrated by the following example: At the time of establishing the setup of a new trust it would be unreasonable to expect the settlor to know how many further trusts, if any, he might wish to establish in the future. This absence of forward looking information would then leave the settlor facing the difficult choice of either: the allocation of the whole of the SNRB available to the first trust established and so removing the ability of the settlor at a later date to allocate any part of this to future trusts; or the only other alternative would be to allocate only a part of the SNRB to the first trust and effectively waste part of the SNRB pending the creation of further trusts, which might or might not come into existence in the future One of the major consequences of the current provisions is that they impact where the allocation of the SNRB cannot be reduced where the first charge to tax has arisen to a trust The above leads us to conclude, in order for the proposed changes to be seen as workable and fair, amendments to the proposed provisions will be required which offer the option that, should a 10 year charge be made resulting in a nil return due to the amount of SNRB available to the trust, it should be possible for any deemed surplus SNRB to be reallocated to another trust if desired by the settlor Under the current rules pension death benefits paid under a pension trust will be treated as relevant property from the date of payment to another trust. However the date used for the ten year anniversary charge on these payments will be based on the date the member joined the transferring pension scheme.

10 4.36 Property initially settled in the receiving trust will have a different ten year anniversary date based on the date the trust was originally established by the settlor. The result of this is that IHT could be suffered in cases where a pension death benefit is paid from a pension trust to a nominated recipient trust just before a ten year charge is due, meaning that an IHT charge would then apply In the spirit of trust simplification we have already looked at the issues that will need to be addressed for pension payments made under a deed poll structure para (above). It is AAT s view that now might be a good time to also consider the extending of the relief under s58 (2a)(B) IHTA 1984 as a potential workable solution for this timing issue encountered for payments under a pension trust and the interaction of this for new pension trusts established after the 6 June Q4: Are there any aspects of the existing rules that would no longer be necessary under the new rules? 4.38 If our understanding is correct the related settlements rule in section 62 of IHTA 1984 will, as a result of these proposals, become redundant. Q5: Are there any other impacts for example on cost or equality that should be taken into account? 4.39 We acknowledge that the condoc sets out a number of examples of the calculations and the amount of tax payable under the proposed new IHT charges compared against the old rules As part of our response to this question we set out a further example of the likely impact of these proposals: Example Case Study- John A Widower John has recently made a new Will following the death of his wife (June) directing his estate to be shared equally between two inter vivos discretionary trusts created during his lifetime, one for each of his two children Sam, Sara and their families On John s death, shortly after the trusts were created, 350,000 from the estate was settled into each trust under the terms of his Will Ten years after the trusts were establishment the settlement had increased in value to 500,000 in each trust and no distributions have been made over this accounting period.

11 4.41 If in this example John died before 7 June 2014, the pre-existing (old) rules will apply. On the ten year anniversary the tax payable by each trust will be 10,500 (if the NRB is then 325,000) as each of the two trusts will benefit from their own NRB ( 500, ,000 x 6%) By comparison, if John was to die after 6 June 2014 the new rules would apply. The IHT payable on the ten year anniversary will depend on the SNRB that each trust enjoys So if John, as Settlor, made an election to split the SNRB equally between each trust, assuming that the SNRB is 325,000, the IHT payable will be 20,250 for each trust ( 500, ,500 x 6%) 4.44 Each trust would still have a NRB of up to 325,000 available to them less the value of capital introduced to the trust when established but with no means of utilising this in the future as any new property introduced to the trusts after 6 June 2014 would, under these current proposals, now need to be accounted for as a separate fund within the trust The effect of the new rules in this example would be to almost double the amount of IHT payable with no options open to the trustees to offset this liability against the unused NRB they would hold, which is unfair and can only help confirm an increase in IHT revenue yields for HMRC is to be expected The actual financial cost to the trustees would be considerably higher than the IHT due as additional fees would be incurred in reporting this liability and in raising the extra funds needed to pay these costs should the trustees retain professional advisers If John (or his executors within two years of his death) does not elect to allocate any of the SNRB each trust will pay 6% of the full value in the trust at the 10 year anniversary and so will be liable for 30,000 per trust further increasing revenue for HMRC, as no other contingency options have been provided for the trustees However, if John did not undertake any IHT planning using trusts during his lifetime or have any provisions for these included in his Will and just left his estate directly to be divided equally between his two children, each family would be liable for up to 200,000 of IHT if, at the date of death of the child, the value of the inheritance had increased to 500,000 ( x 40%) The above has historically been basic estate planning as a result all pre-existing trusts created to receive money or assets left by Will (as in John s case) will be affected by the proposed provisions in respect of additions to existing trusts post 6 June 2014.

12 4.50 The situation will be similar for existing trusts created to receive pension death benefits under deed poll based pension schemes structures will now be caught by the introduction of these new rules once a death triggers the payment of benefits to the trust The proposed measures will also impact on a large number of trusts set up prior to the 7 June 2014 initially with a loan from the settlor to the loan trust trustees or by a combination of a small gift and loan Typically in the case of such arrangements the settlor will set out in their Will or by way of a codicil for the outstanding loan, if any, on death to be given to the loan trust trustees As a result of these proposals trustees will now, very likely, incur additional administrative costs due to the fact that they, very possibly, will need to seek professional advice in respect of such loan waivers passed to ensure that they fully understand the compliance implications Settlors of such trusts will also need to incur further expenses in order to review/amend their Wills with their professional advisers as a result of these changes Under these proposals the simple practice of gifting the value of the loan outstanding to the loan trust trustees will now be regarded as adding property to the trust, so bringing the value of the loan within the new rules In all such instances it is our suggestion that some form of provision will need to be introduced to safeguard the interest of these existing trusts where, from such actions, the actual real financial value of the trust property does not change only the extent of the current liabilities attaching to the trust for accounting purposes The shifting of responsibility for reporting onto the settlor for the allocation of the proposed SNRB rather than falling on the trustees will still impose an extra administrative and compliance burden on trustees In practice this will mean would-be trustees will have to carry out more extensive due diligence before agreeing to act in such a capacity in order to protect both themselves and the compliance position of the trust. This is because there will now be sanctions against trustees if HMRC establishes that they have been careless in allocating the settlor s available SNRB We can also see instances where, contrary to over allocating the available SNRB by trustees, an SNRB may not actually be used at all by eligible trusts through uncertainty. For example in the case of smaller trusts who may not benefit from professional advice. In addition, practitioners will still have to obtain detailed information in order to advise their settlor clients.

13 4.60 Inevitably these measures to be introduced by HMRC under the banner of simplification to reduce complexity and administrative burdens will, if not adequately considered and amended, simply introduce another set of rules which we believe will not be fair and will impact greatly on a number of existing trusts and potentially be seen only to increase the IHT yields in the future for the Exchequer As stated in the condoc this acknowledges that these changes are likely to increase the number of trusts requiring periodic or exit charge calculations and therefore must be expected to increase IHT tax yields. Q6: Should the simplified method for calculating ten year and exit charges proposed for relevant property trusts be extended to trusts that fall within the relevant charging provisions for trusts? 4.62 We suggest from an equity perspective trustees acting for existing trusts should be given the option to use the new simplified calculation method or to maintain the existing method of calculation AAT wishes it to be noted that the condoc is silent over whether trusts would also share the settlors SNRB We also feel that this condoc would have benefitted from the inclusion of example calculations for trusts. 5 CONCLUSIONS 5.1 AAT is disappointed that a model has been selected and continued to be used for the basis of these further discussions which was suggested by only a small group of interested stakeholders at the time of the 2013 consultation. 5.2 We are also disappointed that greater consideration was not given to the overwhelming consensus put forward at the time of the 2013 consultation for alternative arrangements to be explored. The introduction of a renewable SNRB, or a true realistic life-time allowance amount for trusts within a charging regime that is both flexible for the size of trust and purpose of the arrangement, would be viewed as fair. Such as in the case for the nomination of pension death benefits and the use of life assurance policies, which would be viewed as fair and help achieve the objectives set for this consultation.

14 5.3 Despite the high proportion of the UK adult population (70%) who have, as of yet, not taken any action to write a Will, many of these individuals will have at least taken action to nominate death benefits under a pension arrangement or effected some form of family protection policy to be held under a simple trust structure alleviating in these cases the delays and complications that can be encountered when dealing with probate. 5.4 The proposals in their current form could result in future family protection polices no longer being settled in trust, thus increasing the value of the deceased estate for IHT and thereby increasing revenue yields to the Exchequer. 5.5 We question the validity of the impact assessment and would like to see further financial modelling of the likely yields expected under the HMRC model in order to provide reassurance that the proposals put forward are in fact expected to be revenue neutral. 5.6 AAT is concerned that the proposals in their current form will not achieve the stated aim of trust simplification 4. Instead we foresee that they introduce new areas of complexity Trustees for the foreseeable future will be required to operate parallel regimes for the calculation of IHT charges as part of their compliance requirements depending on whether a relevant property trust, and potentially this could be extended to include trust that retain an existing NRB or that must also share a SNRB Different regimes may also apply to different funds within the same trust Record keeping and compliance for trustees has the potential to become even more complicated should the trust have more than one settlor with the possibility of multiple separate sets of calculations being required by the trustees if each settlor has funds subject to different regimes. 5.8 AAT considers that it will be incumbent upon HMRC to assist trustees through their provision of a comprehensive range of toolkits and similar resources. 4 Para 1.2 of the HMRC consultation on Inheritance tax: A fairer way of calculating trust charges

15 6 ABOUT THE AAT 6.1 AAT is a professional accountancy body with over 49,600 full and fellow members and 74,000 student and affiliate members worldwide. Of the full and fellow members, there are 4,000 Members in Practice who provide accountancy and taxation services to individuals, not-forprofit organisations and the full range of business types. (Figures correct as at 30 June 2014) 6.2 AAT is a registered charity whose objectives are to advance public education and promote the study of the practice, theory and techniques of accountancy and the prevention of crime and promotion of the sound administration of the law. 6.3 In pursuance of those objectives AAT provides a membership body. We are participating in this consultation not only on behalf of our membership but also from the wider public benefit perspective of achieving sound and effective administration of taxes. 6.4 Thank you for the opportunity to respond to the HMRC consultation document on Inheritance Tax: A fairer way of calculating trust charges. Further engagement If you have any questions arising from our submission or would like to discuss any of the points in more detail then please contact the AAT at: consultation@aat.org.uk and aat@palmerco.co.uk telephone: Aleem Islan Association of Accounting Technicians 140 Aldersgate Street London EC1A 4HY