IHTM27053 - Valuation: foreign rulers and sovereign immunity

Any case or enquiry involving:

• the transfer, whether in lifetime or on death, of assets held in the UK by a foreign ruler
• the treatment for IHT purposes of UK assets held by a foreign ruler
• a claim that although such assets were held in the name of a foreign ruler they were not in his beneficial ownership, or
• in any other circumstances, the principle of sovereign immunity for taxation

must be referred immediately to Litigation