The provisions in Finance Bill 2008 will give IHT protection to pension savings which have had UK tax relief and also to funds in QROPS Plans.
The Trust is outside of the Member’s estate and therefore IHT would not apply.
It is possible that the unauthorised payment consequences could occur but this charge is only likely to be applicable during the required reporting period (5 year non UK residency rule).
Great care is needed in some overseas jurisdictions and detailed advice should be sought in all cases. Whilst UK Inheritance tax may be avoided some jurisdictions may impose their own succession taxes either on the member or the recipient beneficiaries.