IHTM27001 - Foreign property: introduction

From 6 April 2025, for inheritance tax purposes, domicile is replaced by long-term UK residenceÌýand you can find details of these rules ²¹³ÙÌýIHTM47000.ÌýA transfer is chargeable to Inheritance Tax if the taxpayer is domiciled (IHTM13000) in the UK (to 5 April 2025) or is a long-term UK resident (from 6 April 2025)Ìý(IHTM47000)Ìýat the time of the transfer, or if the asset that is the subject of the transfer or charge is UK situs (IHTM27071) property.ÌýIf you are in any doubt about the domicile/long-term UK residenceÌýof the taxpayer or the situs of the property concerned you should:Ìý

  • refer the case to Service Technical Support (STS) - if you are in Service.Ìý

  • ³¦´Ç²Ô²õ³Ü±ô³Ù바카라 사이트¯IHTM13000바카라 사이트¯and the sections of these instructions about situs (IHTM27071) if you are in Compliance.Ìý

The situs of property is decided by case law, statute and occasionally double taxation treaties or agreements. If you cannot find guidance on a particular type of asset in these instructions, or the situs of the property is disputed:Ìý

  • refer the caseÌýto (STS), ifÌýyou are in Service.Ìý

  • ask for advice from Technical - if you are in Compliance.Ìý

Certain assets are excluded from the charge to Inheritance Tax if the taxpayer was not domiciled in the UKÌýorÌýwasÌýnot a long-term UK residentÌýat the date of the transfer, regardless of where the assets are. Certain securities issued by international organisations (IHTM27141) are an example of this. If the taxpayer or agent claims that an asset is excludedÌýand you cannot find guidance about that type of asset in these instructions:Ìý

  • refer the caseÌýto STS, if you are in Service.Ìý

  • Consult Technical, ifÌýyou are in Compliance.Ìý

You also need to be aware that the claim to Inheritance Tax can be affected by the way assets outside the UK devolve, even when the taxpayer is domiciled in the UKÌýorÌýisÌýa long-term UK resident. For example, the foreign country may have different legal rules for property held jointly or on trust. Any problems with devolution should be referred to:Ìý

  • STS, if you are in Service.Ìý

  • Technical, if you are in Compliance.