Patrick Soares has pointed that the final point 'IHT and treaty relief' in Meeting points Taxation 11 January 2007 page 45 is incorrect and should read as follows.
After the sentence 'HMRC accept that domicile issues exclude deemed domicile when considering the double tax agreements with France Italy India and Pakistan although if domicile under general law is in Italy India or Pakistan the deemed domicile rules can apply to chargeable lifetime transfers (Inheritance Tax Manual para 13024)' it should read: 'Patrick Soares said that one can get the benefit of the UK/Indian double death duty treaty which will override the deemed domicile rule if at the time of death the particular assets are located outside the UK and the devolution of the same is governed by non-UK law.
'This problem could be overcome with regard to UK located assets by borrowing...
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