The High Court accepted rescission claims concerning deeds of appointment pursuant to employee benefit trusts, where the creation of sub-trusts would otherwise have resulted in unexpected inheritance tax charges. 

Summary 

The High Court accepted rescission claims concerning deeds of appointment pursuant to employee benefit trusts, where the creation of sub-trusts would otherwise have resulted in unexpected inheritance tax (IHT) charges. 

Background 

The claimants sought the rescission of various deeds of appointment executed pursuant to two employee benefit trusts (HFBT and EFRBS) and creating sub-trusts for the benefit of individual beneficiaries and their families. The defendants were beneficiaries of the trusts, who did not oppose the relief sought by the claimants. The trusts were administered on the footing that they were not liable to IHT charges within the relevant