Inheritance Tax Act 1984 Schedule A1 paragraph 6

Tax avoidance arrangements

Paragraph 6 of Schedule A1 is an anti-avoidance provision that prevents taxpayers from using arrangements to sidestep the rules that bring overseas property linked to UK residential property within the charge to inheritance tax.

• Any arrangements whose purpose, or one of whose main purposes, is to gain a tax advantage by avoiding or minimising the effect of paragraph 1 or paragraph 5 of Schedule A1 must be disregarded.
• Where such arrangements exist, overseas property that would otherwise be treated as excluded property may lose that status and become chargeable to inheritance tax.
• "Arrangements" is defined very broadly and includes any scheme, transaction, series of transactions, agreement, understanding (whether or not legally enforceable and whenever entered into), and any associated operations.
• "Tax advantage" takes the same meaning as in section 208 of the Finance Act 2013, which is the definition used for the General Anti-Abuse Rule (GAAR).