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HMRC internal manual

Inheritance Tax Manual

Government securities in foreign ownership: type of security and ownership

If a government security is a FOTRA gilt (IHTM04291) you will have to consider who is beneficially entitled (IHTM04031) to that security to work out whether it is excluded property for Inheritance Tax purposes.

If a worthwhile amount of tax is at stake you should investigate the possibility of a last-minute purchase. Except where the available information reasonably rules out that possibility - for instance, if the amount of interest returned suggests long-term ownership - you should seek specific confirmation that the gilts concerned were in fact registered in the transferor’s, or the trustee’s, name(s) at the date of the relevant transfer.

Technical can give you advice if you discover a last-minute purchae of gilts.