IHTM27270 - Property excluded from Inheritance Tax: specific savings held by taxpayers in Channel Islands or Isle of Man

IHTA84/S6 (3) says that certain savings or securities under Government sponsored schemes are excluded property if the person beneficially entitled to them is domiciled ( IHTM13001) in the Channel Islands or the Isle of Man.

The securities eligible for this exclusion from the tax charge are:

• War Savings Certificates
• National Savings Certificates, including Ulster Savings Certificates; but not National Savings Income Bonds
• Premium Savings Bonds
• Deposits with National Savings Bank or with a Trustee Savings Bank
• Savings under any certified contractual savings scheme within TA88/S326 (commonly known as Save As You Earn or SAYE - scheme).

Other points to note are:

• the exclusion applies not only to securities etc owned by a domiciled Islander absolutely but also to any settled securities in which he has a beneficial interest in possession
• the exclusion does not extend to settled securities in which there is no interest in possession, i.e. which are held on discretionary trusts
• the relevant domicile is that of the transferor (and not the transferee) of the securities, at the time of the transfer
• the deemed domicile provisions of IHTA84/S267 (2) do not apply. Accordingly the transferor's domicile has to be determined under general law.