IHTM27212 - Foreign property: Property excluded from Inheritance Tax: foreign unsettled property

IHTA84/S6 (1) - ‘Unsettled’ is a term used to describe property which is owned absolutely, and not held in a settlement. Unsettled property that is situated (IHTM27071) abroad at the time it is transferred is excluded property if the beneficial owner (IHTM04031): 

  • is not a long-term UK resident at the time of the transfer (transfers on or after 6 April 2025) 

  • is domiciled (IHTM13000) outside the UK at the time of the transfer (transfers before 6 April 2025). 

On the other hand, all unsettled property beneficially owned by someone who is a long-term UK resident (on or after 6 April 2025) or who was domiciled in the UK (before 6 April 2025) is chargeable to IHT, regardless of where it is located.  

In any case where the taxpayer or agent claims that the transferor is not a long-term UK resident (on or after 6 April 2025) or was domiciled abroad (before 6 April 2025) at the time of the transfer, you must check to make sure you have all the appropriate information.