IHTM04261 - Savings of individuals domiciled in Channel Islands or Isle of Man - transfers before 6 April 2025

Until 6 April 2025, IHTA84/S6 (3) provided that certain savings or securities under Government sponsored schemes were excluded property (IHTM04251) if the person (IHTM04052) beneficially entitled (IHTM04031) to them was domiciled (IHTM13000) in the Channel Islands or the Isle of Man. 

The securities eligible for this exclusion from the tax charge were:

  • War Savings Certificates 

  • National Savings Certificates, including Ulster Savings Certificates; but not National Savings Income Bonds 

  • Premium Savings Bonds 

  • Deposits with National Savings Bank or with a Trustee Savings Bank 

  • Savings under any certified contractual savings scheme within S326 of the Taxes Act 1988 (commonly known as Save As You Earn or SAYE scheme). 

Other points to note are:

  • the exclusion applied not only to securities that were owned by a domiciled Islander absolutely but also to any settled securities in which they had a qualifying beneficial interest in possession (IHTM16062), 

  • the exclusion did not extend to settled securities held on relevant property trusts (IHTM42161), 

  • the relevant domicile was that of the transferor (and not the transferee) of the securities, at the time of the transfer, which must have been before 6 April 2025, 

  • by reason of IHTA84/S267 (2) the deemed domicile (IHTM13024) provisions did not apply. So the transferor's domicile has to be determined under general law.