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HMRC internal manual

Inheritance Tax Manual

Foreign property: locality of assets (situs): Eurobonds and American depository receipts

We regard the situs of securities dealt with through computerised clearing systems (for example, Euroclear; CEDEL) as determined by the terms of issue of the particular security. Questions about the situs of such securities must be referred to Technical.

Questions about the situs of global depository receipts (GDRs) and American depository receipts (ADRs) must also be referred.