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HMRC internal manual

Inheritance Tax Manual

Foreign property: specific property of visiting forces and staff of Allied Headquarters: qualifying person

The exclusion is available to any of the following persons:

  • IHTA84/S155 (1) - a member of a visiting force of a designated country - who is not a British citizen, a British Dependent Territories citizen, a British National (Overseas) citizen or British Overseas citizen
  • IHTA84/S155 (4) - a member of the Armed Forces of a designated country who is attached to a designated Allied Headquarters and who is not a British citizen within any of the categories mentioned above
  • IHTA84/S155 (3) - a ‘Civilian component’ of a visiting force who is a national of a NATO country but not a British citizen within any of the categories mentioned above. The term ‘civilian component’ applies to civilians attached to visiting forces. It also covers employees of organisations that perform functions for visiting forces which are performed for British forces by organisations like the NAAFI, the Red Cross etc
  • IHTA84/S155 (5) - an employee of a designated Allied Headquarters in the UK who is within the category of such employees agreed by HM Government

No period of duty spent by a qualifying person in the UK is to be regarded as a period of residence here for IHT purposes. And you must not treat such periods as creating a change of a qualifying person’s domicile or residence for those purposes - IHTA84/S155 (2)


The exclusion is not available to spouses, civil partners (IHTM11032) or other dependants of qualifying persons.