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HMRC internal manual

Inheritance Tax Manual

Foreign property: Double Taxation Conventions: proper law of settlement

Usually we do not need to consider which country’s law governs a settlement IHTM04273).

However the French and Italian pre-1975 double taxation conventions have exemptions from Inheritance Tax for settled property situated abroad, that do not apply if the ‘proper law’ is British. This may also be relevant for the convention with the Republic of Ireland. You should refer any cases where this may apply to Technical.