IHTM27270 - Foreign property: property excluded from Inheritance Tax: specific savings held by taxpayers in Channel Islands or Isle of Man (transfers before 6 April 2025)

Until 6 April 2025, IHTA84/S6 (3) provided听that certain savings or securities under Government sponsored schemes were听excluded property if the person beneficially entitled to them was听domiciled (IHTM13001) in the Channel Islands or the Isle of Man.听

The securities eligible for this exclusion were:听

  • War Savings Certificates听

  • National Savings Certificates, including Ulster Savings Certificates; but not National Savings Income Bonds听

  • Premium Savings Bonds听

  • Deposits with National Savings Bank or with a Trustee Savings Bank听

  • Savings under any certified contractual savings scheme within TA88/S326 (commonly known as Save As You Earn or SAYE - scheme).听

Other points to note are:听

  • the exclusion applied听not only to securities that were听owned absolutely but also to any settled securities in which the owner had听a beneficial interest in possession听

  • the exclusion did听not extend to settled securities held on relevant property trusts (IHTM42161),听

  • the relevant domicile was听that of the transferor (and not the transferee) of the securities, at the time of the transfer, which must have been before 6 April 2025,听

  • by reason of IHTA84/S267(2) the deemed domicile (IHTM13024) provisions did听not apply. So听the transferor's domicile has to听be determined听under general law.