Long-term UK residence for IHT (6 April 2025 onwards)

Produced by a Tolley Trusts and Inheritance Tax expert

Trusts and Inheritance Tax

Guidance

This guidance note sets out the conditions that need to be fulfilled to be treated as long-term UK resident (LTUKR). It details the rules for those arriving in and those leaving the UK and the special rule for young persons. It also considers the transitional rules for those who leave the UK before 6 April 2025.

Introduction

The long-term UK residence (UKLTR) rules replace the long-standing domicile rules (see the Domicile for UK inheritance tax guidance note) as the connecting factor for UK inheritance tax purposes from 6 April 2025. The UKLTR status of an individual will determine whether their overseas assets are within the scope of inheritance tax or are excluded property. Domicile will continue to be important for other purposes (see below).

‘Formerly domiciled residents’ will now be treated in the same way as other individuals; there are no longer special rules that apply to them to decide their LTUKR status.

Significance of Long-term UK residence (LTUKR)

If the individual is in scope to UK IHT

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