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HMRC internal manual

Inheritance Tax Manual

Government securities in foreign ownership: FOTRA gilts in unadministered estates

Any FOTRA gilts (IHTM04291) that form part of an unadministered estate (IHTM22011) can qualify as excluded property on a transfer made by a person (IHTM04052) entitled to the whole or part of the unadministered estate. The exclusion will depend on the ordinary residence (IHTM04295) (and domicile (IHTM04296)) of the person entitled to the interest in the estate.


S dies leaving his residuary estate to B and C equally. Before the estate has beenadministered, C - who is domiciled and ordinarily resident abroad - assigns his interest in the estate to the trustees of a discretionary trust. At the time of the assignment the estate includes holdings of exempt securities and some other UK assets.

C’s assignment constitutes a transfer of value that is not a PET (IHTM04057). For the purpose of determining the value transferred,(IHTM04054) C’s interest in FOTRA gilts included in S’s estate is excluded property (IHTM04251) and the securities are therefore left out of C’s estate. The value is ascertained by reference to the remaining assets.