IHTM27142 - Foreign property: securities issued by international organisations: designated as non-UK by Treasury

From 6 April 2025, for inheritance tax purposes, domicile is replaced by long-term UK residenceÌýand you can find details of these rules at IHTM47000.ÌýByÌý³§³Ù²¹³Ù³Ü³Ù´Ç°ù²â InstrumentÌýthe Treasury can designateÌýsecurities issued by certain international organisations as situated outside the UK for the purposes of ICTA88/S324.Ìý

The following organisations have been designated:Ìý

  • The Asian Development Bank - under the International Organisations (Tax Exempt Securities) Order 1984 (SI 1984/1215) made on 2 August 1984Ìý

  • The African Development Bank - under the International Organisations (Tax Exempt Securities) (No 2) Order 1984 (SI 1984/1634) made on 22 October 1984Ìý

  • The European Community, the European Coal and Steel Community, the European Atomic Energy Community, the European Investment Bank - under the European Communities (Tax Exempt Securities) Order 1985 (SI 1985 No 1172) made on 25 July 1985,Ìý

  • The European Bank for Reconstruction and Development - under the International Organisations (Tax Exempt Securities) Order 1991 (SI 1991/1202) made on 16 May 1991.Ìý

Any security issued by these organisations automatically has a foreign situs for Inheritance Tax (IHT), where the event occurred on or after the date of the order. SoÌýit is not subject to IHT unless the transferor is UK domiciledÌý(before 6 April 2025) or a long-termÌýUK resident (on or afterÌý6 AprilÌý2025) at the time of the transfer.