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05 January 2010
A suggestion for completeness
Patrick Hurd, Christophe Gerschel and Philippe Pescayre produced an interesting and excellent article on emigration to France.
Perhaps, for completeness, one might refer to IHTA 1984, s 267(2) and s 158(6), which in effect disapply the deemed domicile provisions for inheritance tax double taxation conventions negotiated before 1975, which include the one with France.
Other countries benefiting from this relaxation are Italy, India and Pakistan.
Richard Sowler TD MA (Oxon) CTA (Fellow), barrister, Middle Temple Lane Chambers
