⚠️ This guide is for general information only and was researched and updated in May 2026. It is not legal or tax advice. Tax and succession laws change frequently and depend on your circumstances. For advice on your situation, please consult a qualified solicitor and tax adviser.
UK Inheritance Tax & Long-Term Residence
The United Kingdom decides whose worldwide estate is within inheritance tax by long-term residence rather than domicile from 6 April 2025. This guide explains the test in plain language and, just as importantly, what it does not change
What changed
For decades, UK inheritance tax (IHT) used domicile, a long-standing legal idea of your permanent home, to decide whether your worldwide assets were taxed. That connecting factor changed to long-term residence from 6 April 2025. The reform follows HM Revenue & Customs guidance (manual references IHTM47000 to IHTM47025).
In broad terms, someone treated as a long-term UK resident may be within IHT scope on their worldwide assets. Someone who is not a long-term resident is generally within scope only on assets situated in the UK. This is a general description of the statutory test, not advice about your own position.
The broad qualifying-years test
A person is broadly treated as a long-term resident if they were UK-resident for at least 10 of the previous 20 tax years before the relevant event, such as death. Whether you were “resident” in a given tax year follows the UK’s statutory residence test, which can be detailed, so the figures below are a guide rather than a calculation of your liability.
The “tail” after leaving the UK
Long-term residents do not fall out of scope the moment they leave. Broadly, scope continues for at least 3 years after leaving, increasing the longer the person was resident, up to a maximum of around 10 years for the longest periods of residence. The exact tail depends on how many of the recent tax years the person was UK-resident.
Three different questions, only one changed
It is easy to assume this change affects everything about an international estate. It does not. Inheritance tax scope, succession, and probate are three separate questions with three different connecting factors. Only the first changed.
Inheritance tax scope
Which assets does UK IHT tax?
Long-term residence (broadly, UK-resident for at least 10 of the previous 20 tax years, plus a tail)
Changed from 6 April 2025Succession & validity
Who inherits, and is the will valid?
Domicile (movable assets), the law where land sits, or habitual residence in some cases
UnchangedProbate (which assets need a will)
Is a UK grant of probate needed?
Where the assets are situated (UK property, bank accounts, shares)
UnchangedWhat this does not change
Domicile still matters
Domicile can still influence who inherits, forced-heirship rules, and whether a will is valid. It has not become irrelevant: it simply no longer drives IHT scope.
Probate follows where assets sit
Whether a UK grant of probate is needed depends on where your assets are situated (UK property, bank accounts or shares), not on your residence or IHT status.
Cross-border planning is unchanged
If you hold assets in more than one country, you may still wish to consider how your wills work together. Read our multi-jurisdiction wills guidance for the wider picture.
When more than one country taxes the same estate
Long-term residence decides whether UK inheritance tax reaches assets held outside the UK. It does not stop another country reaching those same assets. A country may tax an estate because of where the person lived, where the assets are situated, their nationality, or where the beneficiaries live, so one estate can sit within two sets of rules at the same time. That is a common position for someone who has spent a long period in the UK while keeping property, pensions or accounts elsewhere.
Where it happens, relief for the tax paid abroad may be available rather than the same assets simply bearing tax twice over. The UK has a small number of estate and inheritance tax double taxation conventions, given effect by section 158 of the Inheritance Tax Act 1984. Where no convention covers the country concerned, the UK may give unilateral relief for foreign tax charged on foreign assets under section 159 of the same Act. The other country will have its own rules, which may or may not mirror the UK’s.
Which of these applies, and in what order, depends on the facts of an individual estate and on the countries involved. Everything described on this page is general information about how the tests work, not advice about your own liability. If an estate touches more than one country, consider speaking to a qualified adviser in each of them, and see our multi-jurisdiction wills guidance for how the wills themselves fit together.
Frequently asked questions
What changed for UK inheritance tax from 6 April 2025?
From 6 April 2025 the UK stopped using domicile to decide whose worldwide estate is within inheritance tax (IHT) scope and switched to a "long-term residence" test. The change affects IHT scope only: it does not change the rules on who inherits, whether a will is valid, or whether a UK grant of probate is needed.
Who is a "long-term resident" for UK inheritance tax?
In broad terms, someone who was UK-resident for at least 10 of the previous 20 tax years before the relevant event (such as death) may be treated as a long-term resident. Long-term residents may be within UK IHT scope on their worldwide assets; others are generally within scope only on UK-situated assets. The detailed test depends on your circumstances, so this is general information rather than advice.
If I leave the UK, when do I fall out of inheritance tax scope?
There is a "tail" after leaving. Broadly, a long-term resident may stay within IHT scope for at least 3 years after leaving, with the period increasing the longer they were resident, up to a maximum of around 10 years for very long residence. The exact period depends on how many of the recent tax years you were UK-resident.
Does this mean domicile no longer matters?
No. The change is about inheritance tax scope only. Domicile (and, in some situations, habitual residence or the location of assets) can still affect succession: who inherits, forced-heirship rules, and whether a will is valid. Those questions are separate from IHT.
Can two countries tax the same estate?
Yes. Long-term residence decides whether UK inheritance tax reaches assets held outside the UK, but it does not stop another country taxing those same assets under its own connecting factor, such as where the assets are situated or where the beneficiaries live. Where that happens, relief for the foreign tax may be available: the UK has a small number of estate and inheritance tax double taxation conventions, given effect by section 158 of the Inheritance Tax Act 1984, and where no convention applies it may give unilateral relief for foreign tax charged on foreign assets under section 159 of the same Act. Whether relief reaches a particular estate depends on the countries and the facts, so this is general information rather than advice about your own position.
Does being a long-term resident mean I "need a UK will"?
Not on its own. Whether a UK grant of probate (and so often a UK will) is needed is driven by where your assets are situated (for example UK property, UK bank accounts or UK-registered shares), not by your residence or IHT status. Long-term residence and "needing a UK will" are different questions.
Related legal guides
Global Inheritance Tax Guide
Compare inheritance tax rates, thresholds and exemptions across countries, and see long-running abolition trends.
UK Pensions and Inheritance Tax
How unused pension funds and death benefits are expected to count towards the UK estate, what stays outside, and what an executor needs to have organised.
What Happens Without a Will?
Understand the rules of intestacy and how an estate is distributed when there is no valid will.
Property Will Requirements
Learn about special requirements for leaving property in your will, including international property and situs-specific rules.
Put a clear will in place
Inheritance tax scope is only one piece of the picture. A valid, up-to-date will still decides who inherits. Start yours with structured prompts, or find a professional for advice on your own position.
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