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HMRC internal manual

Partnership Manual

From
HM Revenue & Customs
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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Inheritance Tax (IHT): Situs of partnership interest

Property situated outside the UK is excluded property, and so outside the scope of IHT, if the person beneficially entitled to it is an individual domiciled outside the UK. In these circumstances, you may need to consider where the partnership interest is situated. You should first look to the Double Tax Convention that applies to see if it contains any situs rules. Otherwise, situs will be determined in accordance with general law. In relation to a partnership interest, situs will be in the jurisdiction in which the overall management and control of the business is exercised. Detailed guidance is available at IHTM27071.