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HMRC internal manual

Inheritance Tax Manual

Foreign property: money from a life policy: payment made at place other than Head Office

‘Where under the terms of the policy, payment is to be made at some place other than the residence of the head office the monies are deemed to be situated at the place of payment’ (New York Life Insurance Co v Public Trustee [1924] 2 Ch 101).

So, if the policy proceeds are to be paid in the UK the policy proceeds are UK sited and chargeable to Inheritance Tax.