Tax liability on the gift of (ungiven) objects

Question

My clients are the executors of the estate of a resident non-domiciled (non-domiciled of origin but deemed domiciled) deceased whose estate was vast and spanned multiple jurisdictions. In 2008 and 2010 whilst undertaking tax planning in another European jurisdiction the deceased signed documents in accordance with that jurisdiction’s laws which purported to evidence gifts (‘the gifts’) of a number of high value personal chattel items (‘the objects’) to family members (not the spouse) and to the trustees of an offshore family trust (‘the recipients’). However the objects remained as they were at the deceased’s property despite the purported gifts and at all material times were physically situated in England. Under the deceased’s UK will the...