IHTM27161 - Foreign property: Double Taxation Conventions: introduction

Double Taxation Conventions are agreements negotiated between two fiscal authorities. Their main purpose is to provide relief to taxpayers from having to pay full tax in both countries at the same time, on the same property, on the same occasion of charge. They do this in a structured way, as set out in each individual Convention. Another purpose of a Convention is to provide rules for when the two countries should exchange information. (IHTM27163).聽

IHTA84/S158 gives the UK government authority to enter into聽a Double Taxation Convention with the government of any territory outside the United Kingdom in relation to UK Inheritance Tax and a foreign equivalent.聽

The UK currently has agreed Conventions under IHTA84/S158 with the following countries:聽

  • Republic of Ireland聽

  • Netherlands聽

  • South Africa聽

  • Sweden聽

  • United States of America聽

  • Switzerland聽

  • France聽

  • India聽

  • Italy聽

  • Pakistan聽

Details of these are contained in the Inheritance Tax Double Taxation Conventions.聽

For more information on聽the effect of long-term UK residence聽in respect of Double Taxation聽Conventions, please refer to IHTM47070.聽

Whenever you encounter聽a case where one聽of the above Convention countries are聽involved聽the terms of the relevant Convention聽must be considered and applied.