IHTM27202 - Double Taxation Conventions: proper law of settlement

Usually we do not need to consider which country’s law governs a settlement ( IHTM04273).

However the French and Italian pre-1975 Double Taxation Conventions have exemptions from Inheritance Tax for settled property situated abroad, that do not apply if the “proper law” is British. This may also be relevant for the Convention with the Republic of Ireland. Refer all such cases to TG.