Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
, see all updates

Other domicile issues: domicile of life tenant/settlor and exclusion from charge to Inheritance Tax

When considering foreign property in a settlement, whether fixed interest or discretionary, it is the domicile of the settlor(s) that determines whether the property is excluded from the charge to Inheritance Tax (IHT) (see IHTA84/S48 (3)(a) and IHTM27220).

Generally, the domicile of the life tenant (or class of beneficiaries) does not affect the IHT payable on foreign settled property (though their foreign free estate may be excluded property).