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HMRC internal manual

Inheritance Tax Manual

Foreign property: locality of assets (situs): household and personal goods

Household and personal goods (chattels) are situated where they happen to be at the relevant time.

So UK situs chattels are usually chargeable to Inheritance Tax.

But, under IHTA84/S5(1)(b) and IHTA84/S64(2), if a work of art normally kept outside the UK would become liable to IHT because it happened to be in the UK at the relevant date, the liability will be waived if it was brought here solely for public exhibition, cleaning or restoration.

Any case where this provision is invoked, or the taxpayer or agent says it may apply, must be referred to Heritage.