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HMRC internal manual

Inheritance Tax Manual

Government securities in foreign ownership: domicile

For deaths and other chargeable events before 6 April 1998, the beneficial owner (IHTM04031) not only had to be resident or  ordinarily resident (IHTM04295) outside the UK, they also had to be domiciled (IHTM13000) outside the UK. For the purposes of the exclusion, domicile was determined without the aid of the deemed domicile provisions of IHTA84/S267 (IHTM13024). If FOTRA gilts (IHTM04291) are transferred by their beneficial or absolute owner (IHTM04031), the relevant domicile is that of the owner or transferor.


If immediately before the transfer, the securities are settled property in which a qualifying interest in possession (IHTM16062) subsists you will need to consider the domicile of the person (IHTM04052) entitled to that interest, although the position is different where the person is acompany (IHTM04297).