Discretionary trusts, whenever created, and most other forms of lifetime trusts (other than bare trusts and qualifying trusts for disabled persons) established on or after 22 March 2006 are subject to what is known as the ‘relevant property’ regime, which imposes a charge to IHT on the capital value of the trust assets on each 10-year anniversary of the creation of the trust and ‘exit’ charges when capital is distributed or property otherwise ceases to be relevant property.

This charging regime also applies (from 6 April 2008) to pre-22 March 2006 trusts which used to benefit from the favourable 'accumulation and maintenance' regime and were not converted into 18-to-25 or 'capital at 18' trusts prior to 6 April 2008.