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HMRC internal manual

Inheritance Tax Manual

Foreign property: Canadian companies: Nova Scotia companies

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

Every company incorporated under the laws of Nova Scotia must keep a duplicate of any branch register kept outside the province at its registered office in the province. In respect of lifetime transfers, we understand that there is a distinction between:

  • Companies incorporated under the Nova Scotia Companies Acts, in which case a lifetime transfer on a branch register appears to be valid and effective. Accordingly if the securities are registered on a branch register in the UK they must be treated as situated in the UK.
  • Companies incorporated under other Acts, in which case no transfer on a branch register is effective until entered in the principal register. In this case, registered securities may be regarded as situated in Nova Scotia, even though they may be registered on a branch register in the UK.

This restriction does not affect locality for Inheritance Tax purposes on the deceased’s death.

You should refer any problems to Technical