Valuation within discretionary trust

[beckied]

I have two separate discretionary trusts (created on different days) which each hold a 40% shareholding in the same company. If the shares from trust 1 are appointed to trust 2 such that the trustees of 2 now hold 80% we would still have two different anniversary dates for 10 year charge per s 81 ihta 1984 (property held to remain on first trust). However if shares do not qualify for BPR (so their value matters) at each different 10 year anniversary would we be valuing 40% on a pro rata basis of an 80% majority holding (giving a higher value) since trustees of trust 2 now hold all shares or just 40% as a minority holding (if per s 81 shares moving between settlements) held to remain on first trust?

[Lee Young]

I would say you would be valuing half of the 80% holding. It would be an 80% holding trust 2 would then have. Perhaps the reason not to do the transfer contemplated.

[beckied]

Many thanks for taking the time to reply, it’s appreciated and yes a reason not to undertake!