On 13 July 2017, HMRC published some draft legislation for Finance Bill (No.2) 2017 with minor amendments for IHT on enveloped property.

The provisions will be back-dated and apply from 6 April 2017:

  • UK residential property will no longer cease to be UK situs (for Inheritance Tax (IHT) purposes) by being held in an offshore envelope (e.g. a offshore company).
  • Loans made to finance the purchase, enhancement or maintenance of such property will also deemed to be situated in the UK so subject to IHT.
  • Minor interests in UK property will be disregarded, defined as less than 5% of the total interests in  the  property.

Useful guides:

Non-UK domicile status & tax

IHT: estate planning checklist


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