A reversionary interest (IHTM16231) is an item of property, (IHTM04030) separate from the property in which the interest subsists.

If the reversionary interest is itself situated (IHTM27071) outside the UK then, unless the interest is excluded by the main provision in IHTA84/S48 (1), you should proceed as follows

an unsettled reversion will be excluded property (IHTM04251) if the transferor is domiciled (IHTM13000) abroad, IHTA84/S6 (1),

a reversion which is itself comprised in a settlement (IHTM16042) will be excluded if the settlor of the reversion was domiciled abroad when the reversion became comprised in the settlement, IHTA84/S48 (3).

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