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HMRC internal manual

Inheritance Tax Manual

Foreign property: Double Taxation Conventions: certificate of tax paid: Italy

Where a double taxation credit is claimed for tax imposed in Italy or the taxpayer or agent asks for a certificate of the Inheritance Tax paid for the Italian authorities refer the file to Technical for advice.

The Double Taxation Convention between the UK and Italy only covers the Italian equivalent of Inheritance Tax (known as imposta sulla successione). This tax was abolished for all deaths after 25 October 2001 but later reintroduced for deaths on or after 3 October 2006.

You should also consider whether unilateral relief (IHTM27185) applies in respect of Italian taxes that fall outside the scope of the Double Taxation Convention. But it will only apply where the foreign tax is of a character similar to Inheritance Tax or is chargeable on or in connection with death or lifetime gifts. Italian imposta ipotecaria and imposta catastale are not of similar character to Inheritance Tax, because they are chargeable on a normal property purchase as well as on a death transfer.

The provisions of the Convention only cover UK Inheritance Tax that is due on death. They do not cover tax due on immediately chargeable lifetime transfers.