IHTM47072 - Long-term UK residence test: Pre 1975 Double Taxation Conventions
The pre-1975 conventions do not apply deemed domicile. These conventions operate听based on听a听person鈥檚听common law domicile.听听
France听
The convention applies to UK Inheritance Tax and French duty imposed on death but not on occasions other than death听i.e. lifetime transfers.听听
The convention applies a situs code which places assets in one country or the other depending on a person鈥檚 common law domicile.听
Italy听
The convention applies to UK Inheritance Tax and Italian estate and successions tax imposed on death but not on occasions other than death听i.e.听lifetime transfers.听听
The convention applies a situs code which places assets in one country or the other depending on a person鈥檚 common law domicile.听
India听
The convention applies to UK Inheritance Tax and Indian duty imposed on death but not on occasions other than death听i.e.听lifetime transfers.听听
Inheritance tax was abolished in India 1985.听
The UK鈥檚 taxing rights听will be restricted to only the UK assets held in the estate where a person鈥檚 common law domicile is India.听
Pakistan听
The convention applies to UK Inheritance Tax and Pakistan duty imposed on death but not on occasions other than death i.e. lifetime transfers.听
There are听no inheritance tax, estate听or gift taxes in Pakistan.听听
The UK鈥檚 taxing rights听will be restricted to only the UK assets held in the estate where a person鈥檚 common law domicile is Pakistan.