This guidance note is a summary of the information contained in the Double tax relief for IHT and Unilateral relief for IHT guidance notes. Those guidance notes provide more detailed information in the context of cross-border estates.
The removal of domicile as a connecting factor for IHT does not affect double tax relief or the operation of tax treaties. Domicile will remain relevant for these purposes and when used as a concept refers to domicile under the general law.
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 a double tax treaty applies, it should be considered in detail. Double tax treaties can be divided into those entered into before 1975 (estate duty treaties) and more recent treaties.
These include situs codes and have been made with:
France
India
Italy
Pakistan (not including Bangladesh)
They apply only to IHT imposed on death
**Free trials are only available to individuals based in the UK, Ireland and selected UK overseas territories and Caribbean countries. We may terminate this trial at any time or decide not to give a trial, for any reason.
Taxation of loan relationshipsThe vast majority of companies will have loan relationships and so will need to consider how they are taxed under the loan relationship rules. There are also specific provisions dealing with relevant non-lending relationships and other deemed loan relationships.
Corporate interest restriction ― administrative aspectsThe corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns. This guidance note does not include commentary on provisions that are
UK VAT invoice requirementsThis guidance note provides details of the information that must be shown on a valid tax invoice. Businesses supplying goods and services that are liable to the standard or reduced rate of VAT are required to issue a tax invoice to another VAT registered person.If the