For deaths and other chargeable events prior to 6 April 1998,
the beneficial owner (
IHTM04031) not only had to be
ordinarily resident (
IHTM04295) outside the UK, they also
had to be domiciled (
IHTM27000) outside the UK. For the
purposes of the exclusion, domicile is to be determined without the
aid of the deemed domicile provisions of IHTA84/S267. If FOTRA
gilts (
IHTM04291) are transferred by their
beneficial or absolute owner, (
IHTM04031) the relevant domicile is
that of the owner or transferor.
If immediately before the transfer, the securities are
settled property in which a qualifying interest in possession,
(IIP) (
IHTM16000) subsists you will need to
consider the domicile of the person (
IHTM04052) entitled to that interest,
although the position is different where the person is a company. (
IHTM04297)
