SCHEDULE 10 Inheritance Tax on Overseas Property Representing UK Residential Property
Finance (No 2) Act 2017 (2017 c 32) | Legislation

SCHEDULE 10 Inheritance Tax on Overseas Property Representing UK Residential Property

Section 33

Non-excluded overseas property

1

In IHTA 1984, before Schedule 1 insert—

“SCHEDULE A1
Non-Excluded Overseas Property
Part 1
Overseas Property with Value Attributable to UK Residential Property
Introductory
1

Property is not excluded property by virtue of section 6(1) or 48(3)(a) if and to the extent that paragraph 2 or 3 applies to it.

Close company and partnership interests
2

(1)     This paragraph applies to an interest in a close company or in a partnership, if and to the extent that the interest meets the condition in sub-paragraph (2).

(2)     The condition is that the value of the interest is—

(a)     directly attributable to a UK residential property interest, or

(b)     attributable to a UK residential property interest by virtue only of one or more of the following—

(i)     an interest in a close company;

(ii)     an interest in a partnership;

(iii)     property to which paragraph 3 (loans) applies.

(3)     For the purposes of sub-paragraphs (1) and (2) disregard—

(a)     an interest in a close company, if the value of the interest is less than 5% of the

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