Tony, thank you for your reply.
You have to draw a distinction between your assets and those of your son (the recipient of the gift) for the purpose of gift/inheritance tax.
In your question you stated "wish to give my son who is UK resident a monetary gift of £50000. Am I right in thinking that if this gift is given from an Irish based Euro account that there is no UK tax implication for him whereas if the gift is given from a UK based sterling account there is liability for gift/inheritance tax"
As far as your son is concerned, he is a UK resident for tax purposes and will be receiving the monetary gift. Whether the money is paid out of a UK based account or overseas based account, the gift would be free of tax in his hands. Your question was about tax implications for your son receiving a gift of £50,000 and my answer covered that concern.
Generally, if you are domiciled or deemed domiciled in the UK, inheritance tax applies to your worldwide assets. If you are domiciled abroad, UK Inheritance tax applies only to your UK based assets. The reference you have sited from HMRC website would be applicable to you and not your son.
Customer Guide states and I quote" Foreign currency bank accounts - we exclude balances on non-sterling accounts with a bank or the Post Office from inheritance tax on death if they are held by an individual not domiciled, resident or ordinarily resident in the UK."
More information on what is included or excluded for inheritance tax for individuals who are not domiciled in the UK can be found here
I hope this is helpful and answers your question. I am available for any follow up questions you may have, and you can use the reply button to post your follow up questions to the page.
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