SolvedIHTM47072 | Long-term UK residence test: Pre 1975 Double Taxation Conventions
From HM Revenue & Customs · Inheritance Tax Manual
The pre-1975 conventions do not apply deemed domicile. These conventions operate based on a person’s common law domicile.
France
The convention applies to UK Inheritance Tax and French duty imposed on death but not on occasions other than death i.e. lifetime transfers.
The convention applies a situs code which places assets in one country or the other depending on a person’s common law domicile.
Italy
The convention applies to UK Inheritance Tax and Italian estate and successions tax imposed on death but not on occasions other than death i.e. lifetime transfers.
The convention applies a situs code which places assets in one country or the other depending on a person’s common law domicile.
India
The convention applies to UK Inheritance Tax and Indian duty imposed on death but not on occasions other than death i.e. lifetime transfers.
Inheritance tax was abolished in India 1985.
The UK’s taxing rights will be restricted to only the UK assets held in the estate where a person’s common law domicile is India.
Pakistan
The convention applies to UK Inheritance Tax and Pakistan duty imposed on death but not on occasions other than death i.e. lifetime transfers.
There are no inheritance tax, estate or gift taxes in Pakistan.
The UK’s taxing rights will be restricted to only the UK assets held in the estate where a person’s common law domicile is Pakistan.