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Contents

Official guidance
Inheritance Tax Manual

IHTM04000 · How Inheritance Tax is charged

  • IHTM04001 · Summary
  • IHTM04010 · History
  • IHTM04021 · Structure of the charge: main charging provisions
  • IHTM04022 · Structure of the charge: how a disposition becomes a chargeable transfer
  • IHTM04023 · Structure of the charge: what is a disposition?
  • IHTM04024 · Structure of the charge: what is a transfer of value?
  • IHTM04025 · Structure of the charge: what is a deemed transfer of value?
  • IHTM04026 · Structure of the charge: what is an exempt transfer?
  • IHTM04027 · Structure of the charge: what is a chargeable transfer?
  • IHTM04028 · Structure of the charge: what is the value transferred?
  • IHTM04029 · Structure of the charge: what makes up a person's estate?
  • IHTM04030 · Structure of the charge: what is property?
  • IHTM04031 · Structure of the charge: what is meant by beneficially entitled?
  • IHTM04032 · Structure of the charge: how the meaning of estate is extended
  • IHTM04033 · Structure of the charge: how meaning of estate is restricted
  • IHTM04034 · Structure of the charge: what is a general power?
  • IHTM04035 · Structure of the charge: what is general power property?
  • IHTM04036 · Structure of the charge: Dormant Asset Scheme
  • IHTM04041 · Transfers on death: the charging provisions
  • IHTM04042 · Transfers on death: deemed transfer on death
  • IHTM04043 · Transfers on death: what makes up the estate on death
  • IHTM04044 · Transfers on death: what is the value transferred on death?
  • IHTM04045 · Transfers on death: valuing property together
  • IHTM04046 · Transfers on death: changes in value by reason of the death
  • IHTM04051 · Lifetime transfers: the charging provisions
  • IHTM04052 · Lifetime transfers: what is a person?
  • IHTM04053 · Lifetime transfers: what is an individual
  • IHTM04054 · Lifetime transfers: the loss to the transferor’s estate
  • IHTM04055 · Lifetime transfers: loss to estate greater than the value of property given
  • IHTM04056 · Lifetime transfers: loss to estate less than value of property given
  • IHTM04057 · Lifetime transfers: what is a potentially exempt transfer?
  • IHTM04058 · Lifetime transfers: when is a gift made to another individual or to a specified trust?
  • IHTM04059 · Lifetime transfers: when does property becomes comprised in the estate of an individual?
  • IHTM04060 · Lifetime transfers: when is the estate of another individual increased?
  • IHTM04061 · Lifetime transfers: transfers that cannot be potentially exempt transfers
  • IHTM04062 · Lifetime transfers: woodlands subject to a deferred Estate Duty charge
  • IHTM04063 · Lifetime transfers: deemed transfers that are potentially exempt transfers
  • IHTM04064 · Lifetime transfers: deemed potentially exempt transfers
  • IHTM04065 · Lifetime transfers: purchase of a policy linked with an annuity
  • IHTM04066 · Lifetime transfers: what is the value transferred by a potentially exempt transfer?
  • IHTM04067 · Lifetime transfers: what is an immediately chargeable transfer?
  • IHTM04068 · Lifetime transfers: transfer of value by a close company
  • IHTM04069 · Lifetime transfers: alteration in the share capital of a close company
  • IHTM04070 · Lifetime transfers: what is the value transferred by an immediately chargeable transfer?
  • IHTM04071 · Lifetime transfers: introduction to gifts with reservation of benefit
  • IHTM04072 · Lifetime transfers: the charging provisions for gifts with reservation of benefit
  • IHTM04073 · Lifetime transfers: what is the value transferred by a gift with reservation of benefit?
  • IHTM04081 · Settled property: introduction
  • IHTM04082 · Settled property: the charging provisions for an interest in possession trust on death
  • IHTM04083 · Settled property: the charging provisions for an interest in possession trust during lifetime
  • IHTM04084 · Settled property: the charge where an interest in possession comes to an end
  • IHTM04085 · Settled property: the charge where an interest in possession is disposed of.
  • IHTM04086 · Settled property: the charge where the value of settled property is reduced
  • IHTM04087 · Settled property: changes to settled property where IHT is not charged on an interest in possession trust
  • IHTM04088 · Settled property: the charge where an interest in possession comes to an end following a potentially exempt transfer
  • IHTM04089 · Settled property: the charge when both a close company and interest in possession are involved
  • IHTM04090 · Settled property: transfer by a close company apportioned to trustees
  • IHTM04091 · Settled property: alteration in a close company’s capital apportioned to trustees
  • IHTM04092 · Settled property: the charge where a close company is entitled to an interest in possession
  • IHTM04093 · Settled property: what is the value transferred when an interest in possession ceases?
  • IHTM04094 · Settled property: other valuation issues when an interest in possession ceases
  • IHTM04095 · Settled property: the charging provisions for discretionary trusts
  • IHTM04096 · Settled property: charges on property held in relevant property trusts
  • IHTM04097 · Settled property: what is value of property held in discretionary trusts on which tax is charged?
  • IHTM04098 · Settled property: charges on special trusts
  • IHTM04099 · Settled property: charges on accumulation and maintenance trusts
  • IHTM04100 · Settled property: charges on employee and newspaper trusts
  • IHTM04101 · Settled property: charges on protective trusts
  • IHTM04102 · Settled property: charges on trusts for disabled persons
  • IHTM04103 · Settled property: charges on temporary charitable trusts
  • IHTM04104 · Settled property: maintenance funds for historic buildings
  • IHTM04111 · Heritage property: summary
  • IHTM04112 · Heritage property: when a charge to tax arises
  • IHTM04113 · Heritage property: chargeable events under IHTA84/S32
  • IHTM04114 · Heritage property: exceptions to the charge under IHTA84/S32
  • IHTM04115 · Heritage property: chargeable events under IHTA84/S32A
  • IHTM04116 · Heritage property: exceptions to the charge under IHTA84/S32A
  • IHTM04117 · Heritage property: special situations
  • IHTM04118 · Heritage property: double charges
  • IHTM04121 · Woodlands: Summary
  • IHTM04122 · Woodlands: the deferred charge
  • IHTM04141 · Provisions which exclude the Inheritance Tax Act
  • IHTM04151 · Dispositions that are not transfers of value: introduction
  • IHTM04200 · Dispositions by close companies for the benefit of employees
  • IHTM04210 · Waiver or repayment of an amount of remuneration
  • IHTM04220 · Waiver of dividends
  • IHTM04230 · Grant of an agricultural tenancy
  • IHTM04240 · Changes in the distribution of the deceased's estate
  • IHTM04250 · Refund to trustees of Income Tax repayments received by settlor
  • IHTM04161 · Dispositions not intended to confer bounty: outline of IHTA84/S10
  • IHTM04162 · Dispositions not intended to confer bounty: application of the relief
  • IHTM04163 · Dispositions not intended to confer bounty: IHTA84/S10 qualified or excluded
  • IHTM04164 · Dispositions not intended to confer bounty: definitions
  • IHTM04165 · Dispositions not intended to confer bounty: first condition - gift not intended
  • IHTM04166 · Dispositions not intended to confer bounty: second condition - arm's length transaction
  • IHTM04167 · Dispositions not intended to confer bounty: application to settled property
  • IHTM04171 · Dispositions for the maintenance of the transferor’s family: outline of IHTA84/S11
  • IHTM04172 · Dispositions for the maintenance of the transferor's family: definitions
  • IHTM04173 · Dispositions for the maintenance of the transferor's family: maintenance of a spouse or civil partner
  • IHTM04175 · Dispositions for the maintenance of the transferor's family: maintenance of the transferor's children
  • IHTM04176 · Dispositions for maintenance of the transferor's family: maintenance of other people's children
  • IHTM04177 · Dispositions for the maintenance of the transferor’s family: care or maintenance of a dependent relative
  • IHTM04178 · Dispositions for the maintenance of the transferor’s family: meaning of a dependent relative
  • IHTM04179 · Dispositions for maintenance of the transferor's family: meaning of incapacity
  • IHTM04180 · Dispositions for maintenance of the transferor's family: dispositions satisfying IHTA84/S11 in part
  • IHTM04181 · Dispositions for the maintenance of the transferor's family: application to settled property
  • IHTM04191 · Dispositions allowable for income tax or conferring retirement benefits: outline of IHTA84/S12
  • IHTM04192 · Dispositions allowable for income tax or conferring retirement benefits: deductions allowable for income tax
  • IHTM04193 · Dispositions allowable for income tax or conferring retirement benefits: provision by employers for employee's retirements
  • IHTM04251 · Excluded property: introduction
  • IHTM04260 · Foreign `unsettled` property
  • IHTM04261 · Savings of individuals domiciled in Channel Islands or Isle of Man - transfers before 6 April 2025
  • IHTM04262 · Holdings in Open Ended Investment Companies (OEICs) and Authorised Unit Trusts (AUTs)
  • IHTM04263 · Decorations, medals and awards
  • IHTM04271 · Foreign settled property: introduction
  • IHTM04272 · Foreign settled property: when the settlement was made
  • IHTM04273 · Foreign settled property
  • IHTM04274 · Foreign settled property: identifying settled property
  • IHTM04281 · Reversionary interests: introduction
  • IHTM04282 · Reversionary interests: purchased reversions
  • IHTM04283 · Reversionary interests: reversion under own or spouse's/civil partners's settlement
  • IHTM04284 · Reversionary interests: lease for life
  • IHTM04285 · Reversionary interests: interest subject to an annuity
  • IHTM04286 · Reversionary interests: reversions and foreign issues
  • IHTM04291 · Government securities in foreign ownership: introduction
  • IHTM04293 · Government securities in foreign ownership: exclusion from charge to IHT
  • IHTM04294 · Government securities in foreign ownership: type of security and ownership
  • IHTM04295 · Government securities in foreign ownership: ordinary residence
  • IHTM04296 · Government securities in foreign ownership: domicile
  • IHTM04297 · Government securities in foreign ownership: close company with an interest in possession
  • IHTM04298 · Government securities in foreign ownership: relevant property trusts and FOTRA gilts
  • IHTM04299 · Government securities in foreign ownership: conversion to FOTRA gilts and the relevant property trust charge
  • IHTM04300 · Government securities in foreign ownership: anti- avoidance provisions
  • IHTM04301 · Government securities in foreign ownership: exclusion of interest on FOTRA gilts
  • IHTM04302 · Government securities in foreign ownership: exclusion of repayment of Income Tax on FOTRA gilts
  • IHTM04303 · Government securities in foreign ownership: reversionary interest in FOTRA gilts
  • IHTM04304 · Government securities in foreign ownership: FOTRA gilts in unadministered estates
  • IHTM04305 · Government securities in foreign ownership: FOTRA gilts as partnership assets
  • IHTM04306 · Government securities in foreign ownership: list of FOTRA securities in issue at 5 April 1998
  • IHTM04321 · Property of visiting forces: introduction
  • IHTM04322 · Property of visiting forces: qualifying persons
  • IHTM04323 · Property of visiting forces: protection of residence and domicile
  • IHTM04324 · Property of visiting forces: designated countries
  • IHTM04331 · Value left out of account: introduction
  • IHTM04360 · Settled property to which the settlor's spouse, civil partner, widow(er) or surviving civil partner is entitled
  • IHTM04380 · Value left out of account: foreign currency bank accounts
  • IHTM04390 · Value left out of account: overseas pensions
  • IHTM04410 · Value left out of account: interest in possession as remuneration for services as trustee
  • IHTM04341 · Estate Duty surviving spouse exemption: summary
  • IHTM04343 · Estate Duty surviving spouse exemption: application on death
  • IHTM04344 · Estate Duty surviving spouse exemption: application to lifetime events
  • IHTM04345 · Estate Duty surviving spouse exemption: procedures where relief is due
  • IHTM04346 · Estate Duty surviving spouse exemption: procedures where relief is not due
  • IHTM04351 · Reverter to settlor: introduction
  • IHTM04352 · Reverter to settlor: limitations on the relief
  • IHTM04353 · Reverter to settlor: statutory restrictions on relief
  • IHTM04371 · Woodlands: introduction
  • IHTM04373 · Woodlands: the conditions for relief
  • IHTM04374 · Woodlands: the death estate
  • IHTM04375 · Woodlands: the election
  • IHTM04376 · Woodlands: beneficial entitlement under special types of interest
  • IHTM04377 · Woodlands: European Economic Area (EEA) - deaths on or after 22 April 2009
  • IHTM04421 · Compensation for wrongs suffered during World War II: ex-gratia payment to Britons held as prisoners of war by the Japanese
  • IHTM04422 · Compensation for wrongs suffered during World War II: payments to slave or forced labourers or other victims of the German Nationalist Socialist (Nazi) regime
  • IHTM04423 · Compensation for wrongs suffered during World War II: how to apply the relief
  • IHTM04441 · Legal background: the concept of beneficial ownership (England, Wales & Northern Ireland)
  • IHTM04442 · Legal background: connected persons
  • IHTM04470 · Legal background - the meaning of property
  • IHTM04451 · Estate Duty surviving spouse exemption: introduction
  • IHTM04452 · Estate Duty surviving spouse exemption: duty treated as paid in full on the first death
  • IHTM04453 · Estate Duty surviving spouse exemption: restriction on exemption because of non-payment of duty
  • IHTM04454 · Estate Duty surviving spouse exemption: part of fund not dutiable on the first death
  • IHTM04455 · Estate Duty surviving spouse exemption: treatment of income
  • IHTM04456 · Estate Duty surviving spouse exemption: payment of duty ‘in respect of’ any ‘settled property’ since the date of ‘the settlement’
  • IHTM04457 · Estate Duty surviving spouse exemption: meaning of competent to dispose
  • IHTM04458 · Estate Duty surviving spouse exemption: powers where the person is competent to dispose
  • IHTM04459 · Estate Duty surviving spouse exemption: powers where the person is not competent to dispose
  • IHTM04460 · Estate Duty surviving spouse exemption: powers exercisable by will or by deed
  • IHTM04461 · Estate Duty surviving spouse exemption: power to appropriate capital
  • IHTM04462 · Estate Duty surviving spouse exemption: benefits under intestacy (England & Wales)
  • IHTM04463 · Estate Duty surviving spouse exemption: benefits under intestacy and legal rights (Scotland)
  • IHTM04464 · Estate Duty surviving spouse exemption: examples for competency to dispose
  • IHTM04465 · Estate Duty surviving spouse exemption: meaning of parties to a marriage
  • IHTM04311 · Schedule A1/IHTA 84: UK residential property and UK agricultural property
  • IHTM04312 · Schedule A1/IHTA84: close companies and partnership examples
  • IHTM04313 · Para 3 & 4/Schedule A1/IHTA84 relevant loan examples
  • IHTM04314 · Finance (No 2) Act 2017: disposals of company interests, partnership interests, relevant loans and repayments of relevant loans
  • IHTM04315 · Para 7/Sch A1/IHTA84: double taxation arrangements
  • IHTM04316 · Para 6/Schedule A1/IHTA84: targeted anti-avoidance rule and s237(2A)/IHTA: Inland Revenue charge
  • IHTM04317 · Para 20/Schedule 12/Finance Bill 2026: commencement provisions
  • IHTM04142 · Scheme Payments
  • IHTM04174 · Dispositions for the maintenance of the transferor's family: maintenance of children
  • IHTM04342 · Estate Duty surviving spouse exemption: entitlement to relief
  • IHTM04378 · Woodlands: European Economic Area (EEA) - retrospective application for deaths before 22 April 2009
  1. How Inheritance Tax is charged: contents
  2. Government securities in foreign ownership: list of FOTRA securities in issue at 5 April 1998

IHTM04306 | Government securities in foreign ownership: list of FOTRA securities in issue at 5 April 1998

From HM Revenue & Customs · Inheritance Tax Manual

From 6 April 1998 all UK Government securities have FOTRA status, irrespective of the terms of issue of the security. Before that date FOTRA status only applied to certain UK Government securities, which are listed below

SecurityDate(s) for repayment
10½% Conversion Stock 199207/05/1992
10% Conversion Stock 199112/07/1991
9% Conversion Stock 200003/03/2000
9% Conversion Stock 201112/07/2011
9½% Conversion Stock 200112/07/2001
9¾% Conversion Stock 200307/05/2003
8% Conversion Stock 199016/07/1990
7% Conversion Stock 199706/08/1997
Floating Rate Treasury Stock 199909/03/1999
Floating Rate Treasury Stock 200108/07/2001
2% Index Linked Treasury Stock 199223/03/1992
2½% Index Linked Treasury Stock 2024Not later than 17 July 2024
4?% Index Linked Treasury Stock 203022/07/2030
43/8% Index Linked Treasury Stock 200421/10/2004
45/8% Index Linked Treasury Stock 199827/04/1998
5½% Treasury Stock 2008/1210 September 2008 to 10 September 2012
5¾% Funding Loan 1987 – 9105/04/1991
6% Funding Loan 199315/09/1993
6% Treasury Stock 199910/08/1999
6% Treasury Stock 202807/12/2028
6¼% Treasury Stock 201025/11/2010
6½% Funding Loan 1985 – 8701/05/1987
6½% Treasury Stock 200307/12/2003
6¾% Treasury Loan 1995 – 9801/05/1998
6¾% Treasury Loan 200426/11/2004
7% Treasury Stock 200106/11/2001
7% Treasury Stock 200207/06/2002
7¼% Treasury Stock 199830/03/1998
7¼ Treasury Stock 200707/12/2007
7½% Treasury Stock 200607/12/2006
7¾% Treasury Loan 1985 – 8826/01/1988
7¾% Treasury Stock 200608/09/2006
7¾% Treasury Loan 2012/1526 January 2012 to 26 January 2015
8% Treasury Stock 199213/04/1992
8% Treasury Stock 200007/12/2000
8% Treasury Loan 2002/065 October 2002 to 5 October 2006
8% Treasury Stock 200310/06/2003
8% Treasury Stock 201327/09/2013
8% Treasury Stock 201507/12/2015
8% Treasury Stock 202107/06/2021
8¼% Treasury Stock 1987 – 9015/06/1990
8½% Treasury Loan 200028/01/2000
8½% Treasury Stock 200507/12/2005
8½% Treasury Loan 200716/07/2007
8¾% Treasury Loan 1984 – 8610/07/1986
8¼% Treasury Loan 199701/09/1997
8¾% Treasury Loan 201725/08/2017
9% Treasury Loan 1992 – 9628/01/1993
9% Treasury Loan 199417/11/1994
9% Treasury Loan 200813/10/2008
9% Treasury Stock 201206/08/2012
9½% Treasury Loan 199915/01/1999
10% Treasury Loan 199315/04/1993
10% Treasury Loan 199409/06/1994
11%Treasury Loan 199012/02/1990
12½% Treasury Loan 199314/07/1993
12¾% Treasury Loan 199222/01/1992
12¾% Treasury Loan 199515/11/1995
13% Treasury Stock 199015/01/1990
13¼% Treasury Loan 199615/05/1996
13¼% Treasury Loan 199722/01/1997
13¾% Treasury Loan 199323/11/1993
14½% Treasury Loan 199401/03/1994
15½% Treasury Loan 199830/09/1998
15¼% Treasury Loan 199603/05/1996
3½% War Loan
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