Technical Corner - Will Specialty Debts Become Less Special?
A person who is UK-domiciled is subject to inheritance tax (IHT) on worldwide assets. Someone who is neither domiciled nor deemed domiciled in the UK is subject to IHT solely on UK assets. The location of assets can therefore be significant. Most debts are situated in the country of residence of the debtor.
However, it has long been believed that debts made by deed ('specialty debts') are situated where the deed is. This is based on a common law principle originally established in the...
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