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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) is also excluded from the charge to Inheritance Tax:

  • if an existing warrant for repayment has not been cashed 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 received after the date.

A repayment encashed - before a chargeable event - by the person beneficially entitled (IHTM04031) to it is not excluded on that event.