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Double tax relief for IHT

Produced by Tolley in association with
Trusts and Inheritance Tax
Guidance

Double tax relief for IHT

Produced by Tolley in association with
Trusts and Inheritance Tax
Guidance
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Where a double tax treaty has been entered into between the UK and a foreign territory, double tax relief for inheritance tax (IHT) will apply.

Where unilateral relief can also apply, the provision that provides the greatest relief can be claimed. See the Unilateral relief for IHT guidance note.

Where a double tax treaty applies it should be considered in detail. Double tax treaties can be divided into those entered into before 1975 and more recent treaties.

Although domicile is removed as the connecting factor for IHT from 6 April 2025 it remains as a common law concept and its relevance for determining issues concerning Wills, succession law, situs of assets and double tax relief remains unchanged. See the Domicile for UK inheritance tax guidance note in general and for details of changes to the domicile rules for UK IHT after 5 April 2025.

Pre-1975 treaties

These include situs codes and have been made with:

  1. •

    France

  2. •

    India

  3. •

    Italy

  4. •

    Pakistan (not including Bangladesh)

They

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