IHTM47072 - Long-term UK residence test: Pre 1975 Double Taxation Conventions

»Ê¹ÚÌåÓýapp pre-1975 conventions do not apply deemed domicile. »Ê¹ÚÌåÓýappse conventions operateÌýbased onÌýaÌýperson’sÌýcommon law domicile.ÌýÌý

FranceÌý

»Ê¹ÚÌåÓýapp convention applies to UK Inheritance Tax and French duty imposed on death but not on occasions other than deathÌýi.e. lifetime transfers.ÌýÌý

»Ê¹ÚÌåÓýapp convention applies a situs code which places assets in one country or the other depending on a person’s common law domicile.Ìý

ItalyÌý

»Ê¹ÚÌåÓýapp convention applies to UK Inheritance Tax and Italian estate and successions tax imposed on death but not on occasions other than deathÌýi.e.Ìýlifetime transfers.ÌýÌý

»Ê¹ÚÌåÓýapp convention applies a situs code which places assets in one country or the other depending on a person’s common law domicile.Ìý

IndiaÌý

»Ê¹ÚÌåÓýapp convention applies to UK Inheritance Tax and Indian duty imposed on death but not on occasions other than deathÌýi.e.Ìýlifetime transfers.ÌýÌý

Inheritance tax was abolished in India 1985.Ìý

»Ê¹ÚÌåÓýapp UK’s taxing rightsÌýwill be restricted to only the UK assets held in the estate where a person’s common law domicile is India.Ìý

PakistanÌý

»Ê¹ÚÌåÓýapp convention applies to UK Inheritance Tax and Pakistan duty imposed on death but not on occasions other than death i.e. lifetime transfers.Ìý

»Ê¹ÚÌåÓýappre areÌýno inheritance tax, estateÌýor gift taxes in Pakistan.ÌýÌý

»Ê¹ÚÌåÓýapp UK’s taxing rightsÌýwill be restricted to only the UK assets held in the estate where a person’s common law domicile is Pakistan.