Commentary

I1.550 Territorial scope of IHT; domicile; double tax relief

IHT, trusts and estates

I1.550 Territorial scope of IHT; domicile; double tax relief

Foreign elements

I1.550 Territorial scope of IHT; domicile; double tax relief

The territorial limits of IHT are set by the excluded property rules. With some minor exceptions (see I9.322–I9.330B for these), all property situated in the UK is potentially chargeable to IHT irrespective of whether it is in UK or foreign ownership, and the charge is also imposed on foreign property in UK ownership. What IHT does not seek to charge is property situated outside the UK (see Division I9.4 for the situs of assets) which is owned beneficially by a person who does not have a UK domicile1

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