Under UK inheritance tax rules in force since 6 April 2025, someone who has been non-UK resident for 10 consecutive tax years is generally no longer a "long-term UK resident", so UK inheritance tax would generally no longer apply to their non-UK assets. UK assets such as UK property, UK bank accounts and UK shares generally remain within UK inheritance tax wherever you live. Depending on how long you lived in the UK before leaving, this point may be reached sooner, and the exact result depends on your tax-residence history and any split years.

How the rules changed in April 2025

From 6 April 2025, UK inheritance tax moved from a test based mainly on domicile to one based on long-term UK residence. You are generally a long-term UK resident in a tax year if you were UK resident for at least 10 of the previous 20 tax years.

If you are a long-term UK resident, your worldwide estate is generally in scope for UK inheritance tax. If you are not, broadly only your UK assets are in scope. 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.

Why 10 years abroad usually ends worldwide exposure

Section 6A of the Inheritance Tax Act 1984 says you are not a long-term UK resident in a tax year if you were non-UK resident for any 10 consecutive tax years during the 19 tax years before it. HMRC describes the test as being "effectively reset" after 10 consecutive years of non-residence, even if you later return.

This is not simply ten years since you moved. Points to note:

  • The test counts UK tax years, which run from 6 April to 5 April, and residence for each year is decided 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.
  • If you become UK resident again, even for one tax year, a run of non-resident years is broken and you start building UK residence years again.

You may leave the net sooner

Many people do not need the full 10 years. Under the tail rules, if you were UK resident for 13 or fewer of the 20 tax years ending with your last UK resident year, you generally stop being a long-term UK resident after three consecutive non-resident tax years. The tail rises by one year for each extra year of residence, up to 10 years for someone resident for all 20.

Transitional rules apply to some people who were not UK domiciled, or were deemed domiciled, on 30 October 2024 and were non-resident in 2025/26. HMRC says these do not apply to people who were UK domiciled under common law on that date, which is likely to cover many British-born expats. Our guide on the residence-based test explains more.

What stays in the UK inheritance tax net

Even after you stop being a long-term UK resident, UK inheritance tax can still apply to UK situated assets, including:

  • UK property, including UK residential property held indirectly through some overseas structures
  • UK bank accounts and UK-listed shares
  • 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%. Our guide to inheritance tax for UAE resident UK nationals covers how this works for UAE-based families.

Illustrative example

Illustrative example only, not a real client.

Tom lived in the UK from birth until 2014, when he moved to Dubai at 40. He was UK domiciled under common law on 30 October 2024, so the transitional rules do not apply. Assume he has been non-UK resident in every tax year since 2014/15 with no split year, and has not returned.

By 2026/27 he has 12 consecutive non-resident tax years, so on these assumptions he is not a long-term UK resident. His Dubai property, UAE bank accounts and offshore investments, worth GBP 1,500,000, would generally be outside UK inheritance tax, assuming none of them is a UK asset. His London flat, worth GBP 600,000, remains in scope.

Assuming the flat is his only UK asset, he has made no lifetime gifts, the residence nil rate band and spouse exemption are not available and there are no debts or reliefs, the taxable amount would be GBP 275,000 (GBP 600,000 less GBP 325,000), and tax at 40% would be GBP 110,000.

Common mistakes

  • Assuming living abroad removes UK property and other UK assets from inheritance tax.
  • Counting calendar years from the move rather than full UK tax years.
  • Forgetting that a split year counts as a UK resident year, and that a return to UK residence can break the run.
  • Ignoring the pension changes for deaths from 6 April 2027.

Sources and further reading

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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.