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HMRC internal manual

Inheritance Tax Manual

Foreign property: inscribed and registered securities: branch registers

Remember that all UK sited assets are subject to Inheritance Tax. This includes most UK sited shares unless they are excluded property (IHTM04151)

If a company has more than one register, and any changes must be recorded on one of the registers, the relevant securities are sited in the place where that register is required by law to be kept - not in the place of the head office of the company

In Brassard v Smith [1925] AC 371. ‘The true test’, per Lord Dunedin, at p 376, is ‘where could the shares be effectively dealt with?’ The last three words were explained by Viscount Maughan in R v Williams [1942] AC 541 at p 558 as meaning ‘effectively dealt with as between the shareholder and the company, so that the transferee will be legally entitled to all the rights of a member.’