IHTM27270 - Foreign property: property excluded from Inheritance Tax: specific savings held by taxpayers in Channel Islands or Isle of Man (transfers before 6 April 2025)

Until 6 April 2025, IHTA84/S6 (3) providedÌýthat certain savings or securities under Government sponsored schemes wereÌýexcluded property if the person beneficially entitled to them wasÌýdomiciled (IHTM13001) in the Channel Islands or the Isle of Man.Ìý

»Ê¹ÚÌåÓýapp securities eligible for this exclusion were:Ìý

  • War Savings CertificatesÌý

  • National Savings Certificates, including Ulster Savings Certificates; but not National Savings Income BondsÌý

  • Premium Savings BondsÌý

  • Deposits with National Savings Bank or with a Trustee Savings BankÌý

  • Savings under any certified contractual savings scheme within TA88/S326 (commonly known as Save As You Earn or SAYE - scheme).Ìý

Other points to note are:Ìý

  • the exclusion appliedÌýnot only to securities that wereÌýowned absolutely but also to any settled securities in which the owner hadÌýa beneficial interest in possessionÌý

  • the exclusion didÌýnot extend to settled securities held on relevant property trusts (IHTM42161),Ìý

  • the relevant domicile wasÌýthat of the transferor (and not the transferee) of the securities, at the time of the transfer, which must have been before 6 April 2025,Ìý

  • by reason of IHTA84/S267(2) the deemed domicile (IHTM13024) provisions didÌýnot apply. SoÌýthe transferor's domicile has toÌýbe determinedÌýunder general law.