In determining for the purposes of this Act the value of the estate immediately before his death of a person to whom this section applies there shall be left out of account the balance on—
any qualifying foreign currency account of his, and
subject to subsection (3) below, any qualifying foreign currency account of the trustees of settled property in which he is beneficially entitled to an interest in possession.
This section applies to a person who ... immediately before his death is neither resident in the United Kingdom nor a long-term UK resident.
Subsection (1)(b) above does not apply in relation to settled property if—
the trustees are resident in the United Kingdom immediately before the beneficiary's death,
the settlor is alive and is a long-term UK resident immediately before the beneficiary's death,
the settlor died on or after 6 April 2025 and was not a long-term UK resident immediately before they died, or
the settlor died before 6 April 2025 and was not domiciled in the United Kingdom when the property became comprised in the settlement.
This section is subject to paragraph 5 of Schedule A1 (non-excluded overseas property).
For the purposes of this section—
the question whether a person is resident ... in the United Kingdom shall, subject to paragraph (b) below, be determined as for the purposes of income tax; but
the trustees of a settlement shall be regarded as not resident ... in the United Kingdom unless the general administration of the settlement is ordinarily carried on in the United Kingdom and the trustees or a majority of them (and, where there is more than one class of trustees, a majority of each class) are resident ... there.
In this section "qualifying foreign currency account" means a foreign currency account with a bank ...; and for this purpose—
"foreign currency account" means any account other than one denominated in sterling, . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
In this section "bank" has the meaning given by section 991 of the Income Tax Act 2007.