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Position before 6 April 2025

The position is as set out in detail in the Domicile for UK inheritance tax guidance note.

Position on or after 6 April 2025

The new rules apply from 6 April 2025 and are set out in detail in the Long-term UK residence for IHT (6 April 2025 onwards) guidance note.

In addition, the remittance basis of taxation was abolished and replaced with a four-year foreign income and gains (FIG) regime. See the Abolition of the remittance basis from 2025/26 guidance note for further details.

Domicile still exists as a common law concept but will have no impact on the inheritance tax position, other than where it is provided that long-term UK residence is treated as domicile for the purposes of tax treaties.