Under UK inheritance tax rules from 6 April 2025, whether your worldwide estate is within UK inheritance tax depends mainly on whether you are a "long-term UK resident", rather than on your domicile. Broadly, you are a long-term UK resident in a tax year if you were UK tax resident for at least 10 of the previous 20 tax years. If you are not, UK inheritance tax generally applies only to your UK assets, subject to specific rules for trusts, transitional cases and certain UK-linked assets.

How the test works

HMRC guidance states that from 6 April 2025, inheritance tax moved from being based on domicile to being based on long-term UK residence. The test is in section 6A of the Inheritance Tax Act 1984.

You are a long-term UK resident for a whole tax year if you were UK resident in at least 10 of the 20 tax years immediately before it. UK residence for each year since 2013/14 is decided under the Statutory Residence Test. Points to note:

  • the test looks back at the previous 20 tax years, not the current one
  • HMRC treats a split year as a full year of UK residence for this test
  • for people under 20, section 6B substitutes the number of whole tax years they have been alive, and half that number (rounded up) instead of 10

If you are a long-term UK resident, UK inheritance tax can apply to your worldwide assets. If you are not, it broadly applies to UK assets only.

The "tail" after you leave the UK

Because the test looks back over 20 years, your status can continue after you leave. HMRC calls this the tail. Its length depends on how many of the 20 tax years ending with your last UK resident year you were UK resident:

  • 13 years or fewer: you generally remain in scope for 3 tax years after leaving
  • 14 to 19 years: one extra year for each extra year of residence, so 14 years gives 4, 15 gives 5, and so on
  • 20 years: you generally remain in scope for 10 tax years

The legislation also provides that if you have been non-UK resident for any 10 consecutive tax years in the previous 19, you are not a long-term UK resident, even if you later return. HMRC describes the test as effectively reset. Your exact position depends on your tax-residence years, any split years and whether you become UK resident again, so the statutory rules need to be applied to your own history.

How it differs from domicile

Under the old rules, many British expats remained UK domiciled for life because they kept links with the UK or could not show an intention to stay abroad permanently. The new test is more mechanical: it turns on counting years of tax residence rather than intentions.

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. HMRC notes, for example, that it may still matter where a double taxation convention uses the concept of domicile. Transitional rules apply to some people who were not UK domiciled, or were deemed domiciled, on 30 October 2024 and were non-UK resident in 2025/26. HMRC says these do not apply to people who were UK domiciled under common law on that date.

Assets still in the UK net

Being outside the long-term residence test does not remove UK assets from UK inheritance tax. UK property, UK bank accounts and UK shares generally remain in scope. 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.

Our guide to non-dom rules, pensions and overseas trusts explains how the test interacts with trusts and pensions, and our guide to inheritance tax for UAE resident UK nationals looks at the UAE angle.

Illustrative example

Illustrative example only, not a real client.

Priya was UK resident from 2001/02 to 2014/15, then moved to Singapore. Assume she has been non-UK resident in every tax year since 2015/16, with no split year, and was UK domiciled under common law on 30 October 2024.

In the 20 years before 2026/27 (2006/07 to 2025/26), she was UK resident in nine (2006/07 to 2014/15). As nine is fewer than 10, she is not a long-term UK resident in 2026/27 on these assumptions. Her non-UK assets would generally be outside UK inheritance tax, while her UK rental flat remains in scope. If she became UK resident again, she would start adding UK residence years and could become a long-term UK resident in a later year.

Common mistakes

  • Assuming that losing UK domicile under the old rules also takes UK assets outside inheritance tax.
  • Counting calendar years rather than UK tax years.
  • Forgetting that a split year counts as a full UK resident year.
  • Assuming the transitional rules for non-doms apply to British-born expats.

Sources and further reading

A regulated financial adviser can help. Get in touch for a free introduction.

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.