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HMRC internal manual

Inheritance Tax Manual

Foreign property: locality of assets (situs): bearer securities

A bearer security is one where the ownership passes by delivery of the document of title. An example would be a security or bond which is not listed on a register. A bearer security is situated, for Inheritance Tax purposes, in the place where the document of title is found at the material time. Special rules apply to securities listed on a register (IHTM27121)

Att Gen v Bouwens [1838] 4 M & W 171, Winans v Att Gen [1910] AC 27. This does not apply to certain qualifying international securities (IHTM27141).