The private client briefing for February 2013

Speciality debts
HMRC recently updated its Inheritance Tax Manual in relation to its view of the situs of ‘specialty debts’ for UK IHT purposes changing its long-established published practice. The revised guidance at IHTM27079 is as follows:

‘A specialty debt is:

• a debt made by deed or
• a deed which records or creates obligations or
• a debt incurred by way of statute or
• a certain type of debt that is given the nature of a specialty debt...