Double taxation of the same property arises where both the UK
and the convention partner have the right to tax that property. The
conventions provide a set of rules to determine which of the
countries should provide relief from that double taxation (under
IHTA84/S158 (1)).
We currently have Conventions for Inheritance Tax purposes
with the countries listed at
IHTM27161
Each convention is different.
You must consider the terms of the relevant Convention in
order to determine what double taxation credit is due. The credit
cannot then be agreed until payment of the foreign tax has been
certified by the relevant convention country. (IHTM27167)
Any matters relating to the Indian, Pakistan or Italian
Conventions should be referred to TG.
If the taxpayer claims unilateral relief under IHTA84/S159 in
addition to, or as well as, Convention relief on the same property,
consider whether both reliefs are applicable (
IHTM27200).
