Inheritance tax: another day, another government U-turn
IHT treatment of specialty debts
The government has back-pedalled on a controversial decision on inheritance tax after widespread criticism. HMRC came under fire when it decided that a type of debt which had historically been exempt from inheritance tax would now be subject to it – going against centuries of legal precedent.
After discussions with professional bodies, it has now changed its position again – though things still aren’t back to how they were before. Let’s take a look at what’s going on.
What’s the history?
The controversy relates to a type of debt called a ‘specialty debt’, which is one owed to someone who is not domiciled in the UK. It’s a kind of debt created by a deed or a seal, not just a normal contract.
Historically, such debts, when owed to a non-dom, have been exempt from UK inheritance tax if the document recording the debt is …
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