Revised by
MALCOLM GUNN CTA
For updates affecting this Division please see Part I0 Updates
Domicile and residence for IHT
I9.200 Changes to the taxation of non-domiciled individuals—IHT
For the latest New Developments, see ND.2621, ND.2740, ND.2751 and ND.2764.
The commentary below describes the rules that are expected to come in from 6 April 2025. This is a summary of the key points of the changes based on the contents of Finance Bill 2025.
The domicile based regime for inheritance tax will be replaced with a residence-based regime from 6 April 2025. At the same time, the remittance basis of taxation will be abolished and replaced with a time-limited foreign income and gains (FIG) regime — see E6.300 for further details. Domicile will still exist as a common law concept but will have no impact on the inheritance tax position.
Long term residence
From 6 April 2025, the test for whether non-UK assets are in scope for IHT will be whether an individual has been resident in the UK
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Web page updated on 17 Mar 2025 16:53