IHTM04291 - 바카라 사이트 securities in foreign ownership: introduction
바카라 사이트�바카라 사이트 securities바카라 사이트� is a term we use to describe securities issued by the Treasury.바카라 사이트疶hese are also known as 바카라 사이트�gilts바카라 사이트�.聽聽The Treasury can issue, and has issued, securities which聽are exempt from UK taxation so long as they are in the beneficial ownership of persons who satisfy the conditions attached (usually that the person is not resident聽or ordinarily resident聽in the UK).바카라 사이트疭ecurities issued with this condition are known as FOTRA (Free of Tax to Residents Abroad) gilts.聽
Gilts are excluded property for inheritance tax purposes if they are in the beneficial ownership of a person who satisfies the conditions on which the gilt is issued聽by the Treasury.聽 Where the security is settled property, the聽beneficiary or beneficiaries concerned聽must satisfy the conditions.聽聽聽
For chargeable events on or after 6 April 2025, all FOTRA securities, whenever issued, are treated as though no domicile condition were included in the requirements.聽聽
The precise terms of the conditions are set out in聽the prospectus under which the gilts were issued. 聽In general: 聽
gilts issued with conditions after April 2013 require the beneficial owner to be non-resident (IHTM13025)聽聽
gilts issued with conditions between April 1998 and April 2013 require the beneficial owner to be ordinarily resident (IHTM13025) outside the UK聽
gilts issued before April 1996聽require the beneficial owner to be domiciled (IHTM13000) and ordinarily resident outside the UK, so if the chargeable event is before 6 April 2025 that domicile condition will remain relevant.聽
On 6聽April 1998, gilts which were issued聽before that date聽without聽conditions were converted to be FOTRA securities with a condition that the beneficial owner is ordinarily resident outside the UK.聽 They will be therefore be聽excluded property for chargeable events on or after 6聽April 1998, but not if the chargeable event was before this.聽聽聽
However聽3陆% War Loan Stock聽issued in 1952 or later was not so converted and聽聽the聽beneficial owner had to be both ordinarily resident and domiciled outside the UK, and the additional聽domicile condition continued to apply to deaths or other chargeable events. 聽This stock was fully聽redeemed聽on聽9 March 2015.