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Home / Simons-Taxes / IHT, trusts and estates / Part I9 Foreign element / Division I9.4 Locality (situs) of assets for IHT / Situs of debts for IHT / I9.421 Situs of simple contract debts for IHT

I9.421 Situs of simple contract debts for IHT

IHT, trusts and estates

I9.421 Situs of simple contract debts for IHT

General rule

The general rule is that a simple contract debt is situated in the country where the debtor resides, because that is the place where it can be recovered¹. It makes no difference that the debt is expressly made payable in a country where the debtor has no place or residence²; this is because although the stipulation of a place of payment entitles the creditor to sue for breach of

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B6.749 ATED—property developers

B4.130 Summary of OECD guidelines on arm's length principle

C2.1020 Employment-related securities options and capital gains

I9.325 Foreign pensions free from IHT

D7.1140 Methods of leaving the REIT regime

C1.106A Annual exempt amount

A1.543 Welsh GAAR

E5.406 Employees of European Union delegations—tax exemptions

E1.1502 Tax treatment of transfers with accrued interest

B5.820 Charity's profits of trade—general liability to income tax

C2.902 Wasting assets—wasting of allowable expenditure

C2.1231 Leases—deemed premiums

C3.304 Rollover relief—expenditure on replacement assets qualifying for relief

C1.511 Use of Mansworth v Jelley losses

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

D6.711 Liquidation—capital gains implications

B2.472 Tax and tax-related expenditure

B2.202 Capital receipts

D1.1422 Calculating NGIE and ANGIE

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