I understand that UK inheritance tax on free estate outside of the UK is not a testamentary expense unless a contrary intention is shown in the will, and, therefore, UK inheritance tax is payable out of the relevant free estate unless there is such a contrary intention (WM&S, 45-47 citing s.200(1) IHTA 1984).
However, I also understand that where the foreign property forms part of the residuary estate, foreign inheritance tax may be treated as part of the cost of getting in the estate and as a testamentary expense (WM&S, 45-48 citing Re Goetze and Re Sebba).
If foreign property forms part of the residue, am I right in thinking that the UK inheritance tax is payable out of the foreign property but the foreign inheritance tax is payable from the residue? It seems a very odd conclusion.