What is the background and principle involved?

Non-UK assets held by the trustees of an excluded property trust settled by a non-UK domiciled individual are generally outside the scope of Inheritance Tax (IHT). This means that non-UK assets such as investments or UK situated investments, excluding residential property, held in an offshore company remain free of IHT charges, even where the settlor becomes UK domiciled or deemed domiciled in the UK, at a later date.

HMRC has long since held the view, and contained in their published guidance, that trust additions made after the acquisition of a UK domicil...