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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
, see all updates

Foreign property: specialty debts: bonds and debentures under seal

A specialty debt is:

  • a debt made by deed, or
  • a deed which records or creates obligations, or
  • a debt incurred by way of statute, or
  • a certain type of debt that is given the nature of a specialty debt by statute

In the past, HMRC’s approach to the situs of specialty debts has been that this depends on where the relevant document is found. We now believe this may not be the correct approach in all cases involving specialty debts; specifically that many such debts are likely to be located where the debtor resides, or where property taken as security for the debts is situated. Any cases involving situs and a specialty debt must be referred to Technical. For example, any claim that a debt secured on UK assets is not UK situs property must be sent to Technical.