IHTM04274 - Foreign settled property: identifying settled property

The expression 바카라 사이트˜property comprised in a settlement바카라 사이트™ in IHTA84/S48 (3) means the items of property (IHTM04030) held in the settlement (IHTM16042) at the time of the chargeable event you are considering. In determining the locality (IHTM27071) of any particular property you should consider the property in its current form and not its previous history. 
 
Example 
 
 Stella, who is never a long-term UK resident (IHTM47000), transfers a house in Germany바카라 사이트¯and some UK securities바카라 사이트¯into a settlement for Xavier (also not a long-term UK resident) for his life with remainder to Yolanda. On Xavier바카라 사이트™s death - the potentially chargeable event - the settled fund consists of:

  • Option 1: a villa in Spain. 

  • Option 2: land in the UK. 

  • Option 3: a house in Spain and some바카라 사이트¯UK securities. 

With Option 1 the villa is excluded property even though it partly represents the proceeds of what was previously UK property (the securities). 

The land in바카라 사이트¯Option 2바카라 사이트¯is not excluded property although it is partly derived from the proceeds of sale of the German house. 

In Option 3 the house in Spain바카라 사이트¯is excluded property but the UK securities are not.