ÀÏ˾»úÎçÒ¹¸£Àû

For the latest New Development, see ND.2751.

Where property comprised in a settlement is situated outside the UK, the property (but not a reversionary interest in the property) is excluded property unless the settlor was domiciled in the UK at the time when the property became comprised in the settlement¹. This rule applies in relation to all chargeable events on and after 22 July 2020. The position for events prior to that date was a matter of dispute and is discussed further below.

Accumulations of income have the same treatment for IHT purposes as the asset from which they arise. Therefore if income bearing shares are excluded property, then income accumulations arising from those shares are equally excluded property, notwithstanding the fact that the accumulations may have arisen at a later time when the settlor has become deemed domiciled in the UK.

For information on the other categories of excluded and exempt property for IHT see I9.311.

For the meaning of 'settlement' and 'settlor' see I5.111 and I5.131 respectively.

The situs of the