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Legislation
Inheritance Tax Act 1984

Crossheading Miscellaneous

  • Section 262 Tax chargeable in certain cases of future payments, etc.
  • Section 263 Annuity purchased in conjunction with life policy.
  • Section 264 Transfers reported late.
  • Section 265 Chargeable transfers affecting more than one property.
  • Section 266 More than one chargeable transfer on one day.
  • Section 267 Persons treated as domiciled in United Kingdom.
  • Section 267ZA Election to be treated as domiciled in United Kingdom
  • Section 267ZB Section 267ZA: further provision about election
  • Section 267ZC Election to be treated as a long-term UK resident
  • Section 267ZD Further provision about elections under section 267ZC
  • Section 267ZE Subject of domicile election treated as a long-term UK resident
  • Section 267ZF Double taxation conventions operating by reference to deemed domicile
  • Section 267A Limited liability partnerships.
  1. Miscellaneous
  2. Double taxation conventions operating by reference to deemed domicile

Section 267ZF | Double taxation conventions operating by reference to deemed domicile F1

From legislation.gov.uk

(1)This section applies to a case in which the application of any arrangements having effect under section 158 (double taxation conventions) depends (to any extent) on whether a person is treated as domiciled in the United Kingdom for the purposes of inheritance tax.

(2)The person is treated as domiciled in the United Kingdom for the purposes of inheritance tax if they are a long-term UK resident.

(3)Sections 276ZC to 267ZE (persons treated as long-term resident by virtue of election) are to be disregarded in applying this section in relation to any arrangements that are specified in an Order in Council made under section 158 of IHTA 1984 before 17 July 2013 (other than by way of amendment by an Order made on or after that date).

(4)Nothing in this section affects the interpretation of any such arrangements as are mentioned in section 158(6) (certain pre-1975 arrangements).

Notes

  1. F1

    Ss. 267ZC-267ZF inserted (6.4.2025) by Finance Act 2025 (c. 8), Sch. 13 paras. 27, 45(1)

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