Inheritance Tax Manual

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).Ìý

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

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

• Republic of IrelandÌý

• NetherlandsÌý

• South AfricaÌý

• SwedenÌý

• United States of AmericaÌý

• SwitzerlandÌý

• FranceÌý

• IndiaÌý

• ItalyÌý

• PakistanÌý

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

For more information onÌýthe effect of long-term UK residenceÌýin respect of Double TaxationÌýConventions, please refer to IHTM47070.Ìý

Whenever you encounterÌýa case where oneÌýof the above Convention countries areÌýinvolvedÌýthe terms of the relevant ConventionÌýmust be considered and applied.