IHTM13032 - Domicile: Effect of Domicile of Life tenant/Settlor

When considering foreign property in a settlement, whether fixed interest or discretionary, it is the domicile of the settlor(s) that determines whether such property is excluded property, ((see IHTA84/S48 (3)(a) and IHTM27210).

Generally, the domicile of the life tenant (or objects) does not affect the IHT payable on foreign settled property (though their foreign free estate may be excluded property).