»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýappre are provisions for the application of the new measure to double taxation arrangements (IHTM27161). »Ê¹ÚÌåÓýappse give the UK taxing rights, irrespective of the terms of the treaty, where either no tax is charged in a non-UK territory on a transfer of value, or there is such a taxÌýand its effective rate is 0%.Ìý

Example 1Ìý

MohandÌýis Indian born and has an Indian domicile (to 5 April 2025 or is not a long-term UK resident after then).ÌýHis main home is in Mumbai. He owns a £5m residential property in Surrey through a Jersey company all ofÌýwhose shares he owns. »Ê¹ÚÌåÓýapp company has no other assets or liabilities. It has a value of £5m. MohandÌýdies. »Ê¹ÚÌåÓýapp UK/India Double Tax treaty gives taxing rights to India, but no tax is charged. »Ê¹ÚÌåÓýapp UK charges Inheritance Tax (IHT) on the full £5m value attributable to the UK property.Ìý

Example 2Ìý

Before 6 April 2025Ìý

Nadine is a farmer and is domiciledÌýin Iowa (to 5 April 2025 or is not a long-term UK resident after then).ÌýShe is not a UK national. Her £1m house in the Scottish highlandsÌýis held via an offshore company. She dies in the USA. »Ê¹ÚÌåÓýapp USA has taxing rightsÌýbut the value of her estate is below the threshold and there is no tax paid in the USA. »Ê¹ÚÌåÓýapp UK charges IHT on the value of the shares that is attributable to the UK property.â€�Ìý

However, if her estate were charged to US Federal Estate Tax then the UK’s charge to IHT is denied by the UK/US Convention. This would also be the case where there was no US tax payable because of a specific relief, such as the special land use valuation for farm assets.