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Contents

Legislation
Inheritance Tax Act 1984

CHAPTER I GENERAL

  • Section 160 Market value.
  • Section 161 Related property.
  • Section 162 Liabilities.
  • Section 162A Liabilities attributable to financing excluded property
  • Section 162AA Liabilities attributable to financing non-residents' foreign currency accounts
  • Section 162B Liabilities attributable to financing certain relievable property
  • Section 162C Sections 162A, 162AA and 162B: supplementary provision
  • Section 163 Restriction on freedom to dispose.
  • Section 164 Transferor’s expenses.
  • Section 165 Tax on capital gains.
  • Section 166 Creditors’ rights.
  • Section 167 Life policies, etc.
  • Section 168 Unquoted shares and securities.
  • Section 169 Farm cottages.
  • Section 170 Leases for life, etc.
  1. Chapter I · GENERAL
  2. Liabilities attributable to financing non-residents' foreign currency accounts

Section 162AA | Liabilities attributable to financing non-residents' foreign currency accounts F1

From legislation.gov.uk

(1)This section applies if—F1

(a)in determining the value of a person's estate immediately before death, a balance on any qualifying foreign currency account (“the relevant balance”) is to be left out of account under section 157 (non-residents' bank accounts), andF1

(b)the person has a liability which is attributable, in whole or in part, to financing (directly or indirectly) the relevant balance.F1

(2)To the extent that the liability is attributable as mentioned in subsection (1)(b), it may only be taken into account in determining the value of the person's estate immediately before death so far as permitted by subsection (3).F1

(3)If the amount of the liability that is attributable as mentioned in subsection (1)(b) exceeds the value of the relevant balance, the excess may be taken into account, but only so far as the excess does not arise for either of the reasons mentioned in subsection (4).F1

(4)The reasons are—F1

(a)arrangements the main purpose, or one of the main purposes, of which is to secure a tax advantage, orF1

(b)an increase in the amount of the liability (whether due to the accrual of interest or otherwise).F1

(5)In subsection (4)(a)—F1

“arrangements” includes any scheme, transaction or series of transactions, agreement or understanding, whether or not legally enforceable, and any associated operations;

“tax advantage” means—

(a)the avoidance or reduction of a charge to tax, or

(b)the avoidance of a possible determination in respect of tax.

Notes

  1. F1

    S. 162AA inserted (with effect in accordance with Sch. 25 para. 3(8) of the amending Act) by Finance Act 2014 (c. 26), Sch. 25 para. 3(1)

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