Inheritance Tax Act 1984 section 158

Double taxation conventions

Section 158 gives the UK government the power to enter into double taxation conventions with foreign governments to prevent inheritance tax being charged twice on the same assets, and sets out the procedural requirements for bringing such conventions into effect.

• The government may make arrangements with foreign territories to provide relief from double taxation where both UK inheritance tax and a similar foreign tax apply to the same property, including taxes charged on death or lifetime gifts
• These arrangements are given legal force through an Order in Council, which must be approved in draft by the House of Commons before being submitted
• The arrangements may cover retrospective cases, property not itself subject to double taxation, and may confer functions on public authorities in either the UK or the foreign territory to resolve matters arising under the convention
• HMRC may share taxpayer information with the relevant foreign government where a convention requires it, overriding normal confidentiality obligations