IHTM04251 - Excluded property: introduction

The term 바카라 사이트˜excluded property바카라 사이트™ is a technical term and covers certain types of property (IHTM04030) which, subject to certain conditions, are outside the charge to Inheritance Tax바카라 사이트¯(IHT). The exclusion applies toÌý

  • property transferred in the lifetime, IHTA84/S3 (2),Ìý

  • owned by individuals at death, IHTA84/S5 (1), andÌý

  • property held in a settlement, IHTA84/S53 (1) and IHTA84/S58 (1)(f).Ìý

Excluded property is different from the property comprisedÌýin an exempt transfer. Only an exempt transfer is relevant for the purposes of IHTA84/S36 to S42 for grossing up (IHTM26121), interaction (IHTM26101) and so on.Ìý

Special factorsÌý

If you are dealing with a deduction for 바카라 사이트˜excluded property바카라 사이트™,Ìýyour investigation will in the main need to consider one or more of the followingÌý

  • the title to and nature of the property concerned, e.g. whether it is owned outright or settled, or whether it is a reversionary interest (IHTM04281)Ìý

  • the locality (IHTM27071) of the propertyÌý

  • the identity of the person beneficially entitled (IHTM04031) to the propertyÌý

    • for transfers on or after 6 April 2025, whether that person is long-term UK resident (IHTM47000)Ìý

    • for transfers before 6 April 2025, that person바카라 사이트™s domicile (IHTM13000) and/orÌýÌý

    • that person바카라 사이트™s ordinary residence (IHTM13025) where appropriate, andÌý

  • in the case of settled foreign property,Ìýthe rules set out at IHTM04273.

You should establishÌýthese or any other relevant facts by reference to the time when the transfer or disposition (IHTM04023) - which would otherwise be within the scope of IHT - was made, unlessÌýthe legislation points you to any different time.Ìý

ExampleÌý

On 6 April 2014, Adrian transferred US $500,000 to his daughter. He died in바카라 사이트¯2016 domiciled in the UK.Ìý

In determiningÌýwhether the lifetime transfer was of excluded property, you should establishÌýthe locality of the cash transferred and Adrian바카라 사이트™s domicile as atÌý6 April 2014. Anything that happened to the cash afterwards바카라 사이트¯(for example,바카라 사이트¯its investment in the UK) or change in Adrian바카라 사이트™s domicile does not normally matter.Ìý

·¡³æ²¹³¾±è±ô±ð바카라 사이트¯Ìý

On 12 May 2025, when Camilla was a long-term UK resident, she transferred a property in Italy to her son.바카라 사이트¯ Camilla dies on 15 November 2031, when she is no longer a long-term UK resident.바카라 사이트¯Ìý

In determiningÌýwhether the lifetime transfer was of excluded property, you consider Camilla바카라 사이트™s long-term UK residence status at the time of the transfer.바카라 사이트¯ As she was long-term UK resident at the time of the transfer, the potentially exempt transfer was not of excluded property and so becomes chargeable on her death in 2031, even though at that time she is no longer a long-term UK resident.