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HMRC internal manual

Inheritance Tax Manual

Foreign property: money from a life policy: policies under seal

Policies by way of deed or under seal are specialty debts (IHTM27079). Where the policy holder is non UK domiciled and there is no evidence to suggest the location of the policy documents has been artificially arranged, HMRC will treat such policies as situated where the deed is to be found. You should refer to Technical any case in which it is claimed that a policy under seal held by a person domiciled in the UK is not situated in the UK.

Most Lloyds policies are embossed with a seal but they are not specialty debts unless they also bear the witnessed personal signature of the General Manager of Lloyds Policy Signing Office. Lloyds policies that do not bear this signature are chargeable to Inheritance Tax in the country where the debtor (the company) resides (IHTM27101).