Under UK inheritance tax rules from 6 April 2025, it is generally between three and 10 consecutive tax years of non-UK residence, depending on how many years you were UK resident before you left. Broadly, someone UK resident for 13 or fewer of the relevant 20 tax years needs three non-resident years, while someone resident for all 20 needs 10. Even then, UK assets such as UK property generally stay within UK inheritance tax, and the exact answer depends on your tax-residence history and any split years.
The long-term residence test
Since 6 April 2025, UK inheritance tax on non-UK assets depends mainly on whether you are a long-term UK resident: broadly, UK resident for at least 10 of the previous 20 tax years. For many individuals, the domestic inheritance tax test now focuses on long-term UK residence rather than domicile. Domicile remains relevant in some treaty, transitional and anti-avoidance contexts.
Because the test looks back over 20 years, leaving the UK does not end your exposure straight away. HMRC calls the period you remain in scope the tail.
How long the tail lasts
Section 6A of the Inheritance Tax Act 1984 sets the tail by reference to the number of UK resident years in the 20 tax years ending with the last tax year you were UK resident:
| UK resident years in that 20-year period | Consecutive non-resident tax years needed |
|---|---|
| 13 or fewer | 3 |
| 14 | 4 |
| 15 | 5 |
| 16 | 6 |
| 17 | 7 |
| 18 | 8 |
| 19 | 9 |
| 20 | 10 |
So for many British-born expats who lived in the UK for the 20 years before leaving, the answer would be 10 consecutive non-resident tax years. Separately, anyone non-UK resident for any 10 consecutive tax years in the previous 19 is not a long-term UK resident. This does not mean ten years abroad automatically resets everything: the result depends on your residence years and what happens if you return.
Points to note:
- Tax years run from 6 April to 5 April, and residence is decided year by year under the Statutory Residence Test.
- If you have split year treatment in the year you leave, HMRC treats that year as a full year of UK residence for this test.
- Becoming UK resident again, even for one tax year, breaks a run of consecutive non-resident years.
Transitional rules for some people
HMRC says people who were UK domiciled under common law on 30 October 2024 are covered by the standard long-term residence rules from 6 April 2025, with no special transitional treatment.
For people not UK domiciled, or deemed domiciled, on 30 October 2024 and non-resident in 2025/26, the old deemed domicile test (15 of the previous 20 years) broadly applies instead. Our guide to inheritance tax for UAE resident UK nationals covers the main scenarios.
What stays in the net however long you are away
Leaving the test generally only removes non-UK assets. UK assets generally stay in scope, including:
- UK property, including UK residential property held through some overseas structures
- UK bank accounts and shares in UK companies
- pension funds: for deaths on or after 6 April 2027, legislation is intended to bring most unused pension funds and certain pension death benefits into the inheritance tax calculation, subject to exclusions (such as certain death in service benefits and dependants' scheme pensions) and detailed rules still being finalised. The treatment depends on the type of arrangement, the member's long-term UK residence status and the nature of the benefit.
The standard nil rate band is GBP 325,000 and the main rate is 40%.
Illustrative example
Illustrative example only, not a real client.
Two people move to Dubai at the start of the 2020/21 tax year and, it is assumed, are non-UK resident in every tax year from then on, with no split year.
- Sam had lived in the UK all his life and was UK domiciled under common law on 30 October 2024. He was UK resident in all 20 tax years to 2019/20, so he needs 10 consecutive non-resident years (2020/21 to 2029/30). On these assumptions he stops being a long-term UK resident from 2030/31.
- Anna moved to the UK from Australia in 2008/09 and was UK resident for 12 tax years (2008/09 to 2019/20). With 13 or fewer UK resident years, she needs three non-resident years (2020/21 to 2022/23), so she would stop being a long-term UK resident from 2023/24. Assuming she was not UK domiciled or deemed domiciled on 30 October 2024, the transitional deemed domicile test does not bring her back in, as she was UK resident for fewer than 15 years.
In both cases, any UK property they keep generally remains within UK inheritance tax.
Common mistakes
- Assuming you leave the UK inheritance tax net the day you leave, or counting from the departure date rather than full UK tax years.
- Breaking a run of non-resident years by becoming UK resident again.
- Forgetting that UK property, and potentially UK pensions for deaths from 6 April 2027, stay in scope.
Sources and further reading
- legislation.gov.uk: Inheritance Tax Act 1984, section 6A
- HMRC Inheritance Tax Manual: long-term UK residence test
- HMRC Inheritance Tax Manual: transitional rules
- GOV.UK: Inheritance Tax on unused pension funds and death benefits
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Last reviewed: October 2026. Tax year: 2026/27. Jurisdictions covered: UK. Rates, legislation and guidance change, so recheck before relying on this. Rules can differ between England and Wales, Scotland and Northern Ireland; tax residence is fact-specific; treaty outcomes depend on residence, domicile or nationality provisions; examples are simplified and omit reliefs, costs, exchange rates and anti-avoidance rules. This is general information, not financial, tax or legal advice. Take advice in the relevant country before acting.