½Û×ÓÊÓƵ

This sub-topic covers the fundamentals of offshore issues in the context of inheritance tax. Firstly it considers domicile ― the basis for charging inheritance tax up until 5 April 2025. After this date, the UK will move to a residence-based inheritance tax system and this is explained in a further guidance note. The deemed domicile rules are explained as well as the situs of assets and the concept of excluded property. Where a non-domiciled individual has an indirect interest in residential property, this will be chargeable to inheritance tax regardless of its situs and this sub-topic covers the rules in detail. Finally, an outline of the double tax relief rules for inheritance tax is provided which links to more detailed notes on the topic.