In short
Since 6 April 2025 the United Kingdom taxes a person who is not a long-term UK resident, meaning UK resident in fewer than 10 of the previous 20 tax years, only on UK assets, at 40 per cent above the 325 000 pound nil-rate band (IHTA 1984 ss. 6(1), 6A and Schedule 1). Where the deceased is a long-term resident and the surviving spouse is not, the spouse exemption is capped at 325 000 pounds (s. 18(2)), and the tax is due six months after the end of the month of death (s. 226).
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Law as read on 12 October 2026.
The long-term residence rule in 2026
The test: you are a long-term UK resident in a tax year if you were UK resident in at least 10 of the 20 tax years immediately before it (IHTA 1984 s.6A(1)).
The date: the rule has applied since 6 April 2025, when it replaced the domicile and deemed domicile rules for inheritance tax.
The consequence: for a long-term UK resident, inheritance tax reaches assets anywhere in the world, not only assets in the United Kingdom.
Residence in each year is decided under the income tax rules, which means the statutory residence test from 2013-14 (s.6A(5)). HMRC treats a split year as a full year of UK residence for this test (IHTM47020). For a person under 20, the window is the number of whole tax years since birth and the threshold is half of it, rounded up; a person under 1 is never a long-term UK resident (s.6B).
Leaving does not end the status at once. It is lost only after a run of consecutive non-resident years, which depends on how many of the last 20 tax years were years of UK residence (s.6A(2) and (3)). After 10 consecutive years of non-residence the 10 out of 20 test starts again from zero.
Transition. A person who was neither domiciled nor deemed domiciled in the United Kingdom on 30 October 2024, and who is non-resident in the tax year 2025-26, is not a long-term UK resident unless they return. A person who was deemed domiciled on 30 October 2024 and is non-resident in 2025-26 remains a long-term UK resident until the start of the fourth year of non-residence. These transitional rules do not apply to a person UK domiciled under common law on 30 October 2024 (IHTM47021).
Trusts. HMRC asks settlors to tell their trustees when their long-term UK residence status changes, as separate trust charges may be due.
Years of UK residence in the last 20 tax years, and the consecutive non-resident years needed before the worldwide charge ends:
| Years resident in the 20 before leaving | Years abroad to leave the charge |
|---|---|
| 10 to 13 | 3 |
| 14 | 4 |
| 15 | 5 |
| 16 | 6 |
| 17 | 7 |
| 18 | 8 |
| 19 | 9 |
| 20 | 10 |
IHTA 1984 s.6A(3)
Sources read on 2 November 2026:IHTA 1984 s.6A, legislation.gov.ukIHTA 1984 s.6B, legislation.gov.ukInheritance Tax if you're a long-term UK resident, GOV.UKHMRC IHTM47020, long-term UK residence testHMRC IHTM47021, transitional provisions
Non-residents: the answer in three lines
- Since 6 April 2025 the test is residence, not domicile: if you have been UK resident in fewer than 10 of the previous 20 tax years, UK inheritance tax reaches only your UK assets.
- Above the 325 000 pound nil-rate band, the rate is 40 per cent, the same as for a long-term UK resident.
- If the deceased is a long-term UK resident and the surviving spouse is not, the spouse exemption is capped at 325 000 pounds, unless the spouse elects to be treated as a long-term UK resident.
| Long-term UK resident | Not a long-term UK resident | Basis | |
|---|---|---|---|
| Exemption or threshold | Nil-rate band of 325 000 pounds. | Same nil-rate band of 325 000 pounds, applied to UK assets. | GOV.UK, Inheritance Tax; IHTA 1984 Schedule 1 |
| Rates | 40 per cent above the band. | 40 per cent above the band. | GOV.UK, Inheritance Tax |
| Situs or scope | Worldwide assets. Long-term resident means UK resident in at least 10 of the previous 20 tax years. | UK assets only; assets outside the UK are excluded property. | IHTA 1984 s. 6(1), s. 6A; GOV.UK, long-term UK resident guidance |
| Spouse | Everything left to a spouse or civil partner is exempt when both are long-term UK residents. | Where the deceased is a long-term resident and the spouse is not, the exemption is capped at 325 000 pounds; the spouse can elect to be treated as long-term resident to lift the cap. | GOV.UK, Inheritance Tax; IHTA 1984 s. 18(2), (2A); s. 267ZC |
| Treaty relief | Treaties in force with Ireland, South Africa, the USA, the Netherlands, Sweden and Switzerland; older Estate Duty treaties with France, Italy, India and Pakistan. | Same treaties; HMRC looks first at the treaty for where an asset is situated. | GOV.UK, Inheritance Tax double taxation relief; IHTA 1984 s. 158 |
| Filing form | Form IHT400 within 12 months of the death if tax is due; tax due six months after the end of the month of death. | Same form and deadlines for the UK estate. | GOV.UK, Tell HMRC the estate value; IHTA 1984 s. 226 |
Compare countries: Inheritance tax for non-residents, by country, 2026
Law as read on 14 October 2026; band, rate, spouse cap, treaties and IHT400 re-read on GOV.UK and legislation.gov.uk on 19 October 2026. Educational only, not personal advice.
Key figures
- The nil-rate band is 325 000 pounds per person and has been frozen since 2009; the freeze now runs to 5 April 2031.
- The residence nil-rate band adds up to 175 000 pounds where the home passes to direct descendants, and is lost at 1 pound for every 2 pounds of estate above 2 000 000.
- Above the bands, the rate is 40 per cent, or 36 per cent where at least a tenth of the baseline amount goes to charity.
- Since 6 April 2025, a person UK resident in at least 10 of the previous 20 tax years is taxed on worldwide assets, under IHTA 1984 s.6A. Domicile no longer matters for this.
- After leaving, worldwide exposure lasts from 3 to 10 tax years, depending on the years of residence.
- The spouse exemption is capped at 325 000 pounds where the deceased is a long-term resident and the surviving spouse is not, under s.18(2).
- There is no UK inheritance tax convention with the United Arab Emirates.
For non-residents
- Scope: a person who is not a long-term UK resident is taxed on UK assets only; assets outside the United Kingdom are excluded property (IHTA 1984 s. 6(1)).
- Long-term resident: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s. 6A).
- Band and rate: nil up to 325 000 pounds, then 40 per cent (IHTA 1984 Schedule 1).
- Spouse: the exemption is capped at 325 000 pounds where the deceased is a long-term resident and the surviving spouse is not (IHTA 1984 s. 18(2)).
- Payment: due six months after the end of the month in which the death occurs (IHTA 1984 s. 226).
Law as read on 12 October 2026.
UK inheritance tax simulator
An estimate for a death in the 2026-27 tax year, under the residence based regime in force since 6 April 2025.
Points to note
- Long-term UK resident under s.6A: the worldwide estate is within the charge, subject to any convention.
- Business and agricultural property relief, lifetime gifts, trusts and pensions are not modelled.
Nothing you enter is stored, sent or logged. The whole calculation runs in your browser.
Worked examples
Three typical cases, worked out with this calculator's own rules. Reliefs it does not model are left out.
| Case | Assumptions | Result | Legal basis |
|---|---|---|---|
| Estate with a flat in the United StatesOfficial example: GOV.UK, Inheritance Tax double taxation relief | AssumptionsLong-term UK resident; estate of 500,000 GBP including a US flat of 35,000 GBP that bore 1,500 GBP of US tax; no spouse, no home to descendants. | ResultTax 70,000 GBP, less a credit of 1,500 GBP: 68,500 GBP payable. | Legal basisIHTA 1984 s. 159 and Schedule 1 |
| Not a long-term UK residentComputed by this calculator | AssumptionsUK resident in 5 of the previous 20 tax years; UK assets of 1,000,000 GBP and assets abroad of 4,000,000 GBP; death in 2026-27. | ResultTax 270,000 GBP on the UK assets only; the assets abroad are excluded property. | Legal basisIHTA 1984 ss. 6(1), 6A and Schedule 1 |
| Home left to the childrenComputed by this calculator | AssumptionsLong-term UK resident; estate of 900,000 GBP including a home of 500,000 GBP left to the children; no spouse. | ResultTax 160,000 GBP, after the 325,000 GBP nil-rate band and the 175,000 GBP residence nil-rate amount. | Legal basisIHTA 1984 ss. 8D, 8E and Schedule 1 |
From domicile to residence
For a century and a half, UK inheritance tax turned on domicile, a common law concept that followed people for life. Finance Act 2025 abolished it for this tax. Since 6 April 2025, UK assets are always within the charge, and assets abroad are within it where the deceased was a long-term UK resident: resident in at least ten of the twenty tax years before the year of death.
Residence is judged year by year under the statutory residence test used for income tax. Below the age of twenty, the test is at least half of the tax years since birth.
The tail after leaving
Leaving the United Kingdom does not end the exposure. The long-term resident status is shed only after a run of consecutive years abroad, which grows with the years spent in the country.
- Ten to thirteen years of residence in the twenty year window: three years abroad.
- Fourteen years: four. Fifteen: five. And so on, one more for each additional year.
- Twenty years of residence: ten years abroad before the worldwide estate leaves the charge.
How the estate is taxed
The tax falls on the estate as a whole, not on each heir's share. The relationship of the heir does not change the rate. It only opens the spouse exemption, and the residence nil-rate band where the home goes to children or grandchildren.
The residence nil-rate band is tapered on the value of the whole estate, not on the taxable part. An estate of 2 350 000 pounds or more loses it entirely, even when most of it passes to a spouse free of tax. Unused bands on a first death pass to the surviving spouse as a percentage, so a couple can shelter up to 1 000 000 pounds.
Four conventions, four different answers
Take the same person: twelve years resident in the United Kingdom, now living abroad, dying with assets outside the country. The United Kingdom taxes those assets under its own law. Whether a convention stops it depends entirely on where that person now lives.
- United Arab Emirates: no convention. The United Kingdom taxes the worldwide estate for the whole tail, and the credit for foreign tax is of no use, since Dubai levies none.
- Switzerland: the 1994 convention generally protects assets outside the United Kingdom, except that the United Kingdom keeps a secondary right over a UK national who is not also Swiss.
- United States: the 1979 convention protects them in the same way, except for a UK national.
- France: the 1963 convention predates 1975 and is untouched by the long-term residence rule. What decides is common law domicile. A Briton who has lived in Paris for twenty years may still be taxed if he never abandoned his domicile of origin.
What this calculator does not cover
Business and agricultural property relief, whose 100 per cent allowance is 2 500 000 pounds from 6 April 2026; gifts in the seven years before death and their taper; trusts; and pension funds, which are due to enter the estate from April 2027. The transitional rules for people who were not UK resident in 2025-26 and not UK domiciled on 30 October 2024 turn on the former domicile tests and are flagged rather than applied.
| Item | 2026-27 |
|---|---|
| Nil-rate band | 325,000 GBP |
| Residence nil-rate band | 175,000 GBP |
| Taper threshold | 2,000,000 GBP |
| Rate above the bands | 40 % |
| Rate with 10 per cent to charity | 36 % |
| Spouse exemption cap, LTR to non-LTR | 325,000 GBP |
| APR and BPR at 100 per cent | 2,500,000 GBP |
IHTA 1984 ss.7, 8D, 18(2), 124D, Sch.1A; FA 2021 s.86 as amended by FA 2026 s.72
| Years resident in the 20 before leaving | Years abroad to leave the charge |
|---|---|
| 10 to 13 | 3 |
| 14 | 4 |
| 15 | 5 |
| 16 | 6 |
| 17 | 7 |
| 18 | 8 |
| 19 | 9 |
| 20 | 10 |
IHTA 1984 s.6A(3)
Questions
› Do non-residents pay inheritance tax in the United Kingdom?
Since 6 April 2025 the United Kingdom taxes a person who is not a long-term UK resident, meaning UK resident in fewer than 10 of the previous 20 tax years, only on UK assets, at 40 per cent above the 325 000 pound nil-rate band (IHTA 1984 ss. 6(1), 6A and Schedule 1). Where the deceased is a long-term resident and the surviving spouse is not, the spouse exemption is capped at 325 000 pounds (s. 18(2)), and the tax is due six months after the end of the month of death (s. 226).
› Do non-residents pay UK inheritance tax?
Always on assets situated in the United Kingdom. On assets abroad, only where they were long-term UK residents: resident in at least 10 of the 20 tax years before death, a status that survives departure for 3 to 10 years.
› I left the UK and live in Dubai. Am I still exposed?
Yes, for the length of the tail if you were a long-term resident, and there is no UK convention with the United Arab Emirates to limit it. UK assets remain taxable indefinitely.
› What is the inheritance tax threshold in 2026?
325 000 pounds per person, plus up to 175 000 pounds where the home goes to direct descendants. Both are frozen until 5 April 2031.
› Can I leave everything to my spouse tax free?
Yes, where both of you are long-term UK residents. Where the deceased is and the spouse is not, the exemption is capped at 325 000 pounds under s.18(2), unless the spouse elects to be treated as a long-term resident.
› Does the France convention protect me if I live in Paris?
Only if your common law domicile is French. The 1963 convention ignores the long-term residence rule. Residence in France alone is not the test.
› Is the domicile of origin still relevant?
Not for the scope of the tax in UK law since 6 April 2025. It remains decisive under the France convention of 1963, which the reform left untouched.
› How many years of UK residence trigger worldwide inheritance tax?
The test: you are a long-term UK resident in a tax year if you were UK resident in at least 10 of the 20 tax years immediately before it (IHTA 1984 s.6A(1)). The consequence: for a long-term UK resident, inheritance tax reaches assets anywhere in the world, not only assets in the United Kingdom.
› How long does UK inheritance tax exposure last after leaving the UK?
Leaving does not end the status at once. It is lost only after a run of consecutive non-resident years, which depends on how many of the last 20 tax years were years of UK residence (s.6A(2) and (3)). After 10 consecutive years of non-residence the 10 out of 20 test starts again from zero.
› Does the long-term residence rule apply to trusts?
HMRC asks settlors to tell their trustees when their long-term UK residence status changes, as separate trust charges may be due.
Sources
Primary sources only: the Inheritance Tax Act 1984 as amended, the conventions as published on legislation.gov.uk, and HMRC guidance. Every figure was checked against an official worked example where one exists.
Statute
- IHTA 1984 s.6A, long-term UK resident
- IHTA 1984 s.6B, rule below the age of twenty
- IHTA 1984 s.8D, residence nil-rate band and taper threshold
- IHTA 1984 s.8E, residence nil-rate amount
- IHTA 1984 s.18, spouse exemption
- IHTA 1984 s.124D, APR and BPR allowance
- IHTA 1984 s.159, unilateral relief for foreign tax
- IHTA 1984 s.267ZF, long-term residence and conventions
- IHTA 1984 Sch. 1A, 36 per cent rate
Conventions
This page is educational and does not constitute legal or tax advice. Nothing you enter is stored, transmitted or logged; the whole calculation runs in your browser. Amounts are in pounds sterling, with no currency conversion.
Compare countries: Inheritance tax for non-residents, by country, 2026
Structuring the estate
Other jurisdictions
Switzerland
Gift and inheritance tax
France
Gift and inheritance tax
United Arab Emirates
Succession, wills and guardianship
United States
Estate tax on a nonresident's US assets
Japan
Inheritance tax, residents and non-residents
South Korea
Inheritance tax, resident or non-resident deceased
Australia
Super and capital gains at death
Russia
Notary duty and tax on gifts
China
Deed tax and income tax on a home
Singapore
Stamp duty and succession
India
Tax on gifts from non-relatives