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Residence-based IHT system from 6 April 2025 ― overview


Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
tag-icon Autumn Budget 2024

Residence-based IHT system from 6 April 2025 ― overview


Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
tag-icon Autumn Budget 2024
imgtext

This guidance note provides an overview of the changes to the inheritance tax system in the UK from a domicile based system prior to 6 April 2025 to a residence-based IHT system for events on and after this date.

Position before 6 April 2025

The position is as set out in detail in the Domicile for UK inheritance tax guidance note.

Position on or after 6 April 2025

The new rules apply from 6 April 2025 and are set out in detail in the Long-term UK residence for IHT (6 April 2025 onwards) guidance note.

In addition, the remittance basis of taxation was abolished and replaced with a four-year foreign income and gains (FIG) regime. See the Abolition of the remittance basis from 2025/26 guidance note for further details.

Domicile still exists as a common law concept but will have no impact on the inheritance tax position, other than where it is provided that long-term UK residence is treated as domicile for the purposes of tax treaties.

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  • 10 Jun 2025 06:40

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