»Ê¹ÚÌåÓýapp

Where an individual is domiciled outside of the UK (IHTM13021), the provisions of IHTA84/S94 (2)(b) need to be considered. »Ê¹ÚÌåÓýappse provisions affect the amount apportioned to the participator. »Ê¹ÚÌåÓýappy do this by excluding from that amount any part of the value that is attributable to the value of property outside the UK.

Foreign company

A transfer of value by

• a company incorporated abroad (hence domiciled abroad - Gasque v IRC [1940] 2 KB 80), of
• property situated abroad

is not excluded property since IHTA84/S6 (1) only applies to individuals.

However, if such a company

• is resident abroad, and
• makes a transfer of exempt Government securities within IHTA84/S6 (2),

they do qualify as excluded property.