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HMRC internal manual

Inheritance Tax Manual

Household goods and personal goods: valuation and technical issues: situs of works of art owned overseas

For Inheritance Tax purposes, household and personal goods are situated where they happen to be at the relevant date. The exception to this is that, under IHTA84/S5(1)(b), 64(2) and 272 tax is not charged in connection with a death or a ten-year anniversary on a work of art if the following three conditions apply:

  • It is normally kept outside the UK
  • It would become liable to Inheritance Tax solely because it happened to be in the UK at the relevant date, and
  • It was brought here for public exhibition, cleaning or restoration (and no other purpose).

If you receive any case where this exemption is mentioned or might apply you must refer it to Heritage immediately.