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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
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Foreign property: securities issued by international organisations: designated as non-UK by Treasury

By Statutory Instrument the Treasury can designate securities issued by certain international organisations as situated outside the UK for the purposes of ICTA88/S324.

The following organisations have been designated:

  • The Asian Development Bank - under the International Organisations (Tax Exempt Securities) Order 1984 (SI 1984/1215) made on 2 August 1984
  • The African Development Bank - under the International Organisations (Tax Exempt Securities) (No 2) Order 1984 (SI 1984/1634) made on 22 October 1984
  • The European Community, the European Coal and Steel Community, the European Atomic Energy Community, the European Investment Bank - under the European Communities (Tax Exempt Securities) Order 1985 (SI 1985 No 1172) made on 25 July 1985,
  • The European Bank for Reconstruction and Development - under the International Organisations (Tax Exempt Securities) Order 1991 (SI 1991/1202) made on 16 May 1991.

Any security issued by these organisations automatically has a foreign situs for Inheritance Tax (IHT), where the event occurred on or after the date of the order. So it is not subject to IHT unless the transferor is UK domiciled at the time of the transfer.