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 ND.2620 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 for at least 10 out of the last 20 tax years immediately preceding the tax year in which the chargeable event occurs. Residence will be determined by using the statutory residence test (SRT). For determining residence for years prior to 2013/14, the old (pre-SRT) rules will be used. Split year treatment under the SRT will count as a full year of residence for IHT.
For an individual 20 years old or younger, the test will
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Web page updated on 24 Mar 2025 07:30