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HMRC internal manual

Inheritance Tax Manual

Foreign property: valuation of assets: foreign rulers and sovereign immunity

Any case that involves:

  • a transfer (either during their lifetime or on their death) of assets held in the UK by a foreign ruler,
  • the question of how assets held in the UK by a foreign ruler are treated for Inheritance Tax purposes,
  • a claim that although UK assets were held in the name of a foreign ruler they were not in their beneficial ownership, or
  • in any other circumstances, the question of sovereign immunity for tax purposes

must be referred immediately to Technical.