Where a settlor had initially established a settlement when he was non-UK domiciled but then contributed additional property at a time when he was deemed UK domiciled, the additional property could also be ‘excluded property’ for IHT purposes. 

On 14 September 1992, when neither domiciled nor deemed domiciled in the UK for inheritance tax (IHT) purposes, an individual settled $100 to create a trust with a Swiss trustee. Additional funds were settled on various occasions between November 1992 and March 2005. On 6 April 2005, the settlor became deemed domiciled in the UK for IHT purposes. On 16 March 2006, additional substantial cash funds were added to the trust. On 3 April 2006, the trustee acquired 12,487 class ‘A’ shares with a par value of €1.25 per share in a foreign company (MIP) from the settlor for €250 and payment was made from the cash funds added to the trust on 16 March 2006. On 25 October 2006, a capital