Settled exempt government securities not subject to a qualifying interest in possession (QIIP — see I5.203) will only be excluded property if all known persons for whose benefit the settled property, or income from it, has been or might be applied, or who are or might become beneficially entitled to an interest in possession in it, are persons who satisfied or satisfy the exemption conditions for the beneficial owner of the securities1. The conditions for exemption are, for most exempt stock, that the relevant persons should be resident2 outside the UK (and, where applicable not domiciled).
For information on the other categories of excluded and exempt property for IHT see I9.311.
The requirement here is a stringent one and the following points should be noted:
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(a)ÌýÌýÌýÌý The condition has to be fulfilled in relation to all the property comprised in the same settlement, not just the exempt government securities3, even if the settled property has been provided by two or more settlors. IHTA 1984, s 44(2), which provides
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