IHTM04291 - Government securities in foreign ownership: introduction
‘Government securitiesâ€� is a term we use to describe securities issued by the Treasury. These are also known as â€�²µ¾±±ô³Ù²õâ€�.ÌýÌýThe Treasury can issue, and has issued, securities whichÌýare exempt from UK taxation so long as they are in the beneficial ownership of persons who satisfy the conditions attached (usually that the person is not residentÌýor ordinarily residentÌýin the UK). Securities issued with this condition are known as FOTRA (Free of Tax to Residents Abroad) gilts.Ìý
Gilts are excluded property for inheritance tax purposes if they are in the beneficial ownership of a person who satisfies the conditions on which the gilt is issuedÌýby the Treasury.Ìý Where the security is settled property, theÌýbeneficiary or beneficiaries concernedÌýmust satisfy the conditions.ÌýÌýÌý
For chargeable events on or after 6 April 2025, all FOTRA securities, whenever issued, are treated as though no domicile condition were included in the requirements.ÌýÌý
The precise terms of the conditions are set out inÌýthe prospectus under which the gilts were issued. ÌýIn general: Ìý
gilts issued with conditions after April 2013 require the beneficial owner to be non-resident (IHTM13025)ÌýÌý
gilts issued with conditions between April 1998 and April 2013 require the beneficial owner to be ordinarily resident (IHTM13025) outside the UKÌý
gilts issued before April 1996Ìýrequire the beneficial owner to be domiciled (IHTM13000) and ordinarily resident outside the UK, so if the chargeable event is before 6 April 2025 that domicile condition will remain relevant.Ìý
On 6ÌýApril 1998, gilts which were issuedÌýbefore that dateÌýwithoutÌýconditions were converted to be FOTRA securities with a condition that the beneficial owner is ordinarily resident outside the UK.Ìý They will be therefore beÌýexcluded property for chargeable events on or after 6ÌýApril 1998, but not if the chargeable event was before this.ÌýÌýÌý
HoweverÌý3½% War Loan StockÌýissued in 1952 or later was not so converted andÌýÌýtheÌýbeneficial owner had to be both ordinarily resident and domiciled outside the UK, and the additionalÌýdomicile condition continued to apply to deaths or other chargeable events. ÌýThis stock was fullyÌýredeemedÌýonÌý9 March 2015.