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Where Taxpayers and Advisers Meet

what determines if an asset is UK based for IHT purposes

simonm3
Posts:2
Joined:Mon Nov 06, 2023 4:59 pm
what determines if an asset is UK based for IHT purposes

Postby simonm3 » Wed May 21, 2025 4:04 pm

After being non-UK resident for 10 years "UK based assets" are still subject to UK IHT. The HMRC manual is a bit vague as to what that means.

Is this correct?:
* UK assets: UK properties; everything in an ISA or SIPP or UK bank account; any shares in UK listed companies; UK domiciled funds
* Non-UK assets: non-UK companies; non-UK domiciled ETFs not held in an ISA or SIPP; foreign currency bank accounts

Does it matter if the broker is UK based (e.g. Hargreaves Lansdown) or is it safer to use an offshore broker?

AGoodman
Posts:2015
Joined:Fri May 16, 2014 3:47 pm

Re: what determines if an asset is UK based for IHT purposes

Postby AGoodman » Thu May 22, 2025 3:23 pm

Mostly correct. The location of a bank account depends on the location of the branch. The actual currency doesn't matter - i.e. a Euro account in London is UK, a sterling account in Jersey is not.

I'm not aware that foreign shares and funds held in an ISA are necessarily UK situs. We've never really had to consider the situs of a SIPP until the rules change next year but I'd imagine it could be UK (rather than the location of the underlying assets).

The location of a broker doesn't usually matter; the location of the custodian (the nominee company which holds the assets managed by the broker platform) should not matter either but if I recall correctly there is a small amount of doubt over that (it gets complicated quickly). Obviously any cash deposits held by a broker (usually by the broker's bank) will usually be in the same jurisdiction as the broker itself.


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