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HMRC internal manual

Inheritance Tax Manual

Government securities in foreign ownership: exclusion of repayment of Income Tax on FOTRA gilts

Repayment of income tax relating to interest on FOTRA gilts (IHTM04291) also falls within the exclusion for such securities

  • if an existing warrant for repayment remains uncashed at the date of the relevant chargeable event
  • in the case of a trust, if the proceeds of an encashed warrant are held - at the date of the chargeable event - by the trustees pending distribution in the administration of the trust, or
  • if the repayment due up to the date of the chargeable event is receivable after the date.A repayment encashed - before a chargeable event - by the person beneficially entitled (

IHTM04031) to the repayment is not eligible for the exclusion on that event.