Readers’ forum: IHT returns for Indian-domiciled late client

A client of mine has just died. He was born in India to Indian parents but lived in the UK from his late teens until the end of his life. He had built up a considerable wealth around the world including owning a property in India which he stayed in on his regular visits to meet members of his extended family. He always regarded himself as Indian and he planned to go back to India at the end of his life. I have on file an old DOM1 ruling from HMRC which agrees that he was domiciled in India.

To what extent can I rely on that ruling when preparing IHT returns on his death? The UK’s deemed domicile rules for IHT are over-ridden by the treaty with India so if he is domiciled as a matter of general law in India his non-UK assets are outside the UK...