PM274500 - Situs of partnership interest

If property is situated outside the UK and the beneficially entitled person is an individual domiciled outside the UK the property will be outside the scope of IHT, as it is excluded property. In these circumstances, you may need to consider where the partnership interest is situated. You should first look to the Double Tax Convention that applies to see if it contains any situs rules. Otherwise, situs will be determined in accordance with general law. In relation to a partnership interest, situs will be in the jurisdiction in which the overall management and control of the business is exercised.

Detailed guidance is available at IHTM27071.