If all or part of the chargeable property is situated outside
the United Kingdom, the case owner’s first priority should be
to consider to what extent, if any, the property or the proceeds of
sale thereof, will be required to discharge the debt due to the
Exchequer.
The case owner should also consider the current residence of
the persons liable for the tax and their residence intentions in
the future. If, having done so, you decide that there is a risk of
tax being lost, either because the assets or the taxpayer are
outside the UK, you should refer the case to DMB for protective
action to be taken.
Protective action should always be considered to protect the
interest of the Exchequer unless the taxpayer is permanently
resident in this country and the value of the property situate
within the jurisdiction is sufficient to discharge in full the
total debt due.
