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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Pre-owned assets: exemptions: foreign element

There are a number of exemptions that apply

  • to a UK-domiciled individual who is not resident in the UK for any year of assessment (IHTM44053), and
  • to foreign domiciliaries (IHTM44054 & IHTM44055).

Note that the Inheritance Tax deemed domicile rules (IHTM13024) apply for the purposes of the POA charge, FA04/Sch15/Para12(4). The application of the deemed domicile rules should be considered at the first day of the year of assessment in question.