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Excluded Property and Non-Domicile: Estate Planning for International Clients

· 22 min

Executive Summary

The Finance Act 2025 replaced domicile with long-term UK residence as the connecting factor for Inheritance Tax, restructuring the excluded property framework from 6 April 2025. Foreign unsettled property is now excluded only when the beneficial owner is not a long-term UK resident under the 10-of-20-year test in section 6A of IHTA 1984. For settled property, the repeal of section 48(3)-(3F) eliminates permanent domicile-based protection, substituting a dynamic test linked to the settlor's long-term residence status at each chargeable event. Pre-30 October 2024 trusts benefit from partial transitional protection -- a gift with reservation exemption and a GBP 5 million cap on relevant property charges per cycle -- but remain exposed to periodic and exit charges. With IHT receipts reaching GBP 7.1 billion in the first ten months of 2025-26, international tax specialists require a systematic framework for excluded property classification, dynamic trust analysis, and compliance under the new regime.

1. Excluded Property Redefined: The Shift from Domicile to Residence

1.1 The Conceptual Transformation

Excluded property was, for four decades, the foundation of IHT planning for non-domiciled individuals. Under the domicile-based system, the framework operated on a binary principle: foreign assets held by individuals domiciled outside the UK fell outside IHT scope entirely, and foreign settled property retained excluded status permanently if the settlor was non-UK domiciled at the time of settlement.12 The Finance Act 2025 (c.8), section 44, dismantled this framework with effect from 6 April 2025, substituting "an individual who is not a long-term UK resident" for "domiciled outside the United Kingdom" throughout the excluded property provisions of IHTA 1984.34

The replacement connecting factor -- long-term UK residence (LTR) -- is defined in new section 6A of IHTA 1984, inserted by Finance Act 2025 section 44(3)(4).5 An individual is an LTR at all times in a tax year if UK tax resident for at least 10 of the previous 20 tax years.5 LTR status resets only after 10 consecutive tax years of non-UK residence, or a shorter period determined by a statutory lookup table based on the number of qualifying years of UK residence within the 20-year window.5 For pre-2013 tax years, residence is determined by historical income tax rules; from 2013 onwards, by the Statutory Residence Test under Finance Act 2013 Schedule 45.5

The shift carries three structural consequences for excluded property analysis. First, the connecting factor is now dynamic rather than permanent: an individual's excluded property status fluctuates as residence years accumulate or expire within the rolling 20-year window. Second, the test is objective and mechanical, removing the subjective intention-based enquiry that characterised common law domicile determinations. Third, the change from a settlement-date test to a chargeable-event-date test for settled property creates ongoing monitoring obligations for trustees and advisors that did not exist under the previous regime.67

1.2 The Enforcement Context

The fiscal significance of excluded property has sharpened materially. IHT receipts reached GBP 7.1 billion in the first ten months of 2025-26, GBP 0.1 billion higher year-on-year, following a record annual figure of GBP 8.2 billion in 2024-25.8 The Office for Budget Responsibility forecasts IHT receipts of GBP 14.5 billion by 2030-31, a 67% increase over five years, driven in part by frozen nil-rate bands (GBP 325,000 NRB and GBP 175,000 RNRB until at least April 2030-31).910 HMRC opened 4,171 IHT enquiries in the year to April 2025, a 38% increase from 3,028 in the prior year, according to Freedom of Information data obtained by Price Bailey.11 The residence-based regime extends the IHT base by capturing formerly non-domiciled individuals whose worldwide assets were previously excluded, and HMRC's enforcement posture reflects the revenue at stake.

2. The Excluded Property Taxonomy Under the New Regime

2.1 Section 6(1): Unsettled Foreign Property

The primary excluded property category remains foreign-situs property held personally. Section 6(1) of IHTA 1984, as amended, provides that property situated outside the United Kingdom is excluded property if the person beneficially entitled to it is an individual who is not a long-term UK resident.34 This mirrors the pre-2025 rule in structure -- the change is solely in the connecting factor. When an individual who is not an LTR acquires LTR status (by accumulating 10 years of UK residence within 20), all foreign personal assets automatically enter IHT scope without any transfer or chargeable event. Conversely, when an LTR ceases to be an LTR (after the required consecutive years of non-UK residence), foreign personal assets resume excluded status.5

2.2 Section 6(1A): Authorised Unit Trusts and Open-Ended Investment Companies

Holdings in authorised unit trusts (AUTs) and shares in open-ended investment companies (OEICs) are excluded property under section 6(1A) if the beneficial owner is not an LTR.312 Although AUTs and OEICs are themselves UK-established vehicles, their treatment as excluded property for non-LTR holders reflects the policy that such holdings function as investment wrappers for the underlying foreign exposure. HMRC guidance at IHTM04262 confirms this treatment applies to the beneficial interest in the units or shares, not to the underlying assets of the fund.12

2.3 Sections 6(1B)-(1C): Decorations and Awards

Relevant decorations and awards for valour, military service, emergency responder service, or public service recognition remain excluded property regardless of the holder's LTR status.3 These provisions were not amended by the Finance Act 2025 and operate independently of the residence-based framework.

2.4 Section 6(2): Treasury Securities

Treasury securities issued with conditions of exemption under the Finance Act 1931 or Finance (New Duties) Act 1915 remain excluded property when held by specified persons.3 This category has diminished practical significance but remains available where qualifying gilt-edged securities carry the exemption condition.

2.5 Section 48(1): Reversionary Interests

Reversionary interests are excluded property under section 48(1) unless they were acquired for consideration, the settlor or spouse is or has been beneficially entitled, or certain conditions under section 74A(1) are satisfied.13 This general exclusion under section 48(1) was not substantively altered by the Finance Act 2025 and continues to operate independently of the LTR framework. The repeal of subsections (3) to (3F), by contrast, removed the domicile-based protection for foreign settled property generally -- not for reversionary interests specifically. The dynamic LTR-based test now applies to determine whether foreign settled property qualifies as excluded property at each chargeable event, but the section 48(1) reversionary interest exclusion remains intact and is unaffected by this change.137

2.6 Section 6(5) and Schedule A1: The Anti-Avoidance Carve-Out

Section 6(5) subjects all excluded property provisions to Schedule A1 of IHTA 1984, introduced by the Finance (No. 2) Act 2017.314 Schedule A1 prevents indirectly held UK residential property from qualifying as excluded property regardless of the owner's or settlor's LTR status.1415 The provisions operate as follows:

  • Interests in close companies or partnerships are not excluded property to the extent their value is attributable to UK residential property interests.15
  • "Relevant loans" used to acquire, maintain, or enhance UK residential property are not excluded property.15
  • Money or collateral held as security for such loans is not excluded property.15
  • Anti-avoidance provisions disregard arrangements whose main purpose is to secure a tax advantage by avoiding Schedule A1.14

Schedule A1 remains a significant trap for international clients who hold UK residential property through offshore corporate or partnership structures. The interposition of a non-UK company between the beneficial owner and the UK property does not achieve excluded property status; the anti-avoidance provisions look through the structure to the underlying residential property interest. HMRC guidance at IHTM04311 confirms this treatment and sets out the valuation methodology for attributing residential property value through corporate layers.15

3. Foreign Settled Property: The Dynamic Exposure

3.1 The Pre-2025 Position: Permanent Protection

Before 6 April 2025, foreign property comprised in a settlement was excluded property if the settlor was domiciled outside the UK at the time the property became comprised in the settlement, under former section 48(3) of IHTA 1984.12 This was a one-time test applied at the date of settlement. Once established, excluded property status was permanent regardless of subsequent changes in the settlor's domicile -- even if the settlor became UK-domiciled or deemed domiciled, the foreign settled property retained its excluded status.2 This permanence made excluded property trusts the cornerstone of non-domiciled IHT planning for decades.

3.2 The Post-2025 Position: Dynamic Status

The Finance Act 2025 repealed section 48(3)-(3F) entirely with effect from 6 April 2025, removing the permanent domicile-based protection for foreign settled property.137 The determination of excluded property status for foreign settled property is now governed by the settlor's LTR status at the date of the chargeable event, creating three distinct scenarios:1617

Settlor alive at the chargeable event. Foreign property is excluded if the settlor is not an LTR at that date. If the settlor is an LTR, the property is within IHT scope and subject to the relevant property regime -- periodic charges at each 10-year anniversary (up to 6% effective rate) and proportionate exit charges on distributions.16

Settlor died on or after 6 April 2025. Foreign property is excluded if the settlor was not an LTR immediately before death.16

Settlor died before 6 April 2025. The old domicile-based test continues to apply: property is excluded if the settlor was non-UK domiciled when the property entered the settlement.16 This preserves the pre-existing position for historic settlements where the settlor predeceased the regime change.

The dynamic test means that trust assets can move in and out of excluded property status as the settlor's LTR status changes over time.76 When a settlor becomes an LTR, the trust loses excluded property status and enters the relevant property regime. When the settlor subsequently ceases to be an LTR (after the required consecutive years of non-UK residence), the trust regains excluded property status -- but the transition itself may trigger a proportionate exit charge under section 65 IHTA 1984.1819

3.3 The QIIP Dual-Test Requirement

For qualifying interest in possession (QIIP) settlements, a material additional complexity arises. The HMRC Trusts and Estates Newsletter of April 2025 confirms that foreign property in a QIIP is excluded only if both the settlor and the life tenant are not long-term UK residents at the time of the chargeable event.20 This dual test represents a significant departure from the pre-2025 position, where only the settlor's domicile at settlement was relevant.2017

The practical implications are acute for cross-generational trusts. Consider a trust established by a non-LTR parent (settlor) with a life interest held by an adult child who has lived in the UK for 12 years and qualifies as an LTR. Under the pre-2025 regime, the trust would have enjoyed permanent excluded property status based on the parent's non-UK domicile at settlement. Under the post-2025 QIIP dual test, the child's LTR status alone is sufficient to remove excluded property status from the foreign settled property, exposing it to IHT on the life tenant's death. Advisors must now assess the residence profile of both settlor and life tenant at each chargeable event.20

3.4 Proportionate Charge Calculations

ICAEW's technical analysis confirms that where trust assets transition between excluded and non-excluded status, the 10-year anniversary and exit charge calculations use a reduced number of quarters to reflect periods when assets qualified as excluded property.6 The charge is based on the original settlement date, but the effective rate is adjusted by reducing the number of complete successive quarters in the relevant period during which the property was within IHT scope.619

HMRC guidance at IHTM47023 provides worked examples of the proportionate charges arising on 6 April 2025 when the regime transitioned.19 Where a settlor was UK-domiciled at common law but is not an LTR under the new test, foreign settled property may transition from relevant property to excluded property, triggering a proportionate exit charge. Conversely, where a settlor was non-UK domiciled but meets the LTR test, their trust assets lose excluded property status and enter the relevant property regime for the first time. HMRC's Katerina and Ping scenarios illustrate both directions of transition.19

4. Transitional Provisions: Scope and Limitations

4.1 GWR Exemption for Pre-30 October 2024 Settlements

Trusts settled and funded before 30 October 2024 by non-UK domiciled settlors benefit from transitional protection under the gift with reservation (GWR) rules.2122 Foreign property that was excluded property in the settlement immediately before 30 October 2024 is disregarded for GWR purposes even if the settlor is an LTR at death.21 This protection is subject to strict conditions:

  • The property must remain settled and situated outside the UK (or invested in AUTs/OEICs) at the date of death.21
  • UK-situs property held within the trust does not benefit from the GWR transitional protection.21
  • New additions to the settlement after 30 October 2024 are outside the scope of this protection.22

The practical effect is that a settlor of a pre-30 October 2024 trust can remain a beneficiary of the foreign property in the trust without triggering the 40% death charge under the GWR rules.21 This protection addresses a specific risk: absent the transitional provision, a settlor who retained a benefit from a trust that had lost excluded property status would face a GWR charge on the full value of the trust fund at death. The transitional protection removes this death charge -- but does not remove the relevant property charges that arise during the settlor's lifetime.

4.2 The GBP 5 Million Cap on Relevant Property Charges

A separate transitional measure, implemented through new section 75B of IHTA 1984, caps the relevant property IHT charges for pre-30 October 2024 excluded property trusts at GBP 5 million per 10-year cycle.23 The mechanics are as follows:

  • The cap applies only to settled property that was excluded property at 30 October 2024.23
  • Property must be situated outside the UK at the time of the relevant charge.23
  • Tax paid on exits during the cycle reduces the remaining cap available for the 10-year anniversary charge.23
  • The first period (6 April 2025 to the first 10-year anniversary) is pro-rated.22

The cap should not be mischaracterised as rendering former excluded property trusts effectively tax-free. A GBP 5 million cap over a 10-year cycle represents a substantial liability for trusts that previously paid no IHT whatsoever. The maximum effective rate of 6% on the relevant property within the 10-year charge means that the cap bites only where the chargeable value exceeds approximately GBP 83 million (GBP 5 million divided by 6%). For trusts below this threshold, the standard relevant property charge applies without modification. The cap therefore protects only the largest former excluded property trusts from the full impact of transition charges.2324

4.3 Transitional Treatment for Non-Residents in 2025-26

HMRC guidance at IHTM47021 confirms that non-domiciled or deemed domiciled individuals who are non-UK resident in 2025-26 benefit from a transitional assessment under the pre-April 2025 deemed domicile test (15 years of UK residence in 20) rather than the new LTR test (10 years in 20).25 This transitional provision addresses individuals who would have become LTR under the new 10-year test but had not yet triggered deemed domicile under the old 15-year test. The protection is available for a maximum of four consecutive years of non-UK residence; if the individual subsequently returns to the UK, the new LTR rules apply from that point.255

4.4 The 6 April 2025 Transition Charges

The commencement date itself generated chargeable events for certain trusts. HMRC guidance at IHTM47023 addresses two categories of transition:19

Domiciled but not LTR. Settlors who were UK-domiciled at common law (with trusts within the relevant property regime under the old rules) but who do not meet the LTR test see their foreign trust assets transition from relevant property to excluded property on 6 April 2025. This transition triggers a proportionate exit charge under section 65 IHTA 1984.1918

Non-domiciled but LTR. Settlors who were non-UK domiciled (with trusts enjoying excluded property status under the old rules) but who meet the LTR test see their foreign trust assets lose excluded property status and enter the relevant property regime. The trust becomes subject to periodic and exit charges from 6 April 2025, with the 10-year charge calculated on a proportionate basis reflecting the date of entry into the regime.196

5. Practical Compliance and Planning Framework

5.1 Decision Framework for Advisors

International tax specialists advising clients with cross-border assets should apply the following systematic analysis:

Step 1: Determine LTR status. Establish the client's UK residence history for the previous 20 tax years. For years before 6 April 2013, apply historical income tax residence rules; for subsequent years, apply the Statutory Residence Test under Finance Act 2013 Schedule 45.5 Calculate whether the 10-of-20-year threshold is met. Project forward to identify the tax year in which LTR status will be acquired (for arriving clients) or when it will expire (for departing clients under the graduated tail period).5

Step 2: Classify all assets by situs and holding structure. Distinguish UK-situs assets (always within IHT scope), foreign-situs personal assets (excluded if beneficial owner is not LTR), and settled property (subject to the dynamic test at each chargeable event).316

Step 3: Apply the relevant excluded property test to each asset. For unsettled foreign property, apply section 6(1) based on the beneficial owner's LTR status. For AUT/OEIC holdings, apply section 6(1A). For settled property, determine the settlor's LTR status at the next anticipated chargeable event. For QIIPs, assess both the settlor's and the life tenant's LTR status.320

Step 4: Check Schedule A1. For any asset held through an offshore company, partnership, or other indirect structure, determine whether the value is attributable to UK residential property interests. If so, the asset cannot qualify as excluded property regardless of LTR status.1415

Step 5: Assess transitional protection. For trusts settled before 30 October 2024 by non-UK domiciled settlors, confirm eligibility for the GWR exemption and the GBP 5 million cap. Verify that the property was excluded property at 30 October 2024, remains foreign-situs, and has not been supplemented by post-30 October 2024 additions.212223

Step 6: Consider spousal election implications. Where the client's spouse is not an LTR, evaluate whether an election under section 267ZC IHTA 1984 to be treated as an LTR is advantageous (for full spousal exemption on transfers from an LTR spouse) or detrimental (by bringing the electing spouse's worldwide assets into IHT scope and transforming their foreign property from excluded to non-excluded).2627 The election ceases to have effect after 10 consecutive tax years of non-UK residence.26

Step 7: Calculate IHT exposure and identify planning opportunities. Quantify the IHT exposure for each category of asset. For trusts entering the relevant property regime, model the 10-year periodic charge and proportionate exit charges. For clients approaching LTR status, consider the timing implications of establishing or restructuring trusts before the 10-year threshold is met. For departing clients, calculate the graduated tail period and the date on which LTR status will expire.56

5.2 Updated IHT Form Requirements

HMRC updated the IHT400 and IHT100 forms from April 2025 to incorporate the residence-based regime:20

  • IHT401a replaces IHT401 for cases involving individuals who are not long-term UK residents, requiring detailed residence history rather than domicile analysis.20
  • D31a and D31b are new schedules for transitional situations where the interaction between the old domicile-based rules and the new LTR test must be documented.20
  • Trustees must report the LTR status of settlors and, where relevant, life tenants at each chargeable event.20

Offshore trustees face a particular compliance burden. The monitoring obligation requires access to the settlor's UK residence information at each 10-year anniversary and exit event.20 Where trustees are located outside the UK and the settlor is not co-operative or has died, obtaining reliable residence data may present significant practical difficulties. Advisors should consider establishing information-sharing protocols at the time of settlement or when reviewing existing trust arrangements under the new regime.

5.3 Worked Example: The Transitioning Settlor

A non-UK domiciled individual (Settlor A) established a trust in 2010 with GBP 10 million of foreign-situs assets, and was not UK tax resident at the time of settlement. Under the pre-2025 rules, the trust enjoyed permanent excluded property status based on the settlor's non-UK domicile at settlement. Settlor A moved to the UK in 2015 and has been UK tax resident continuously since. By April 2025, Settlor A has 10 years of UK residence within the 20-year window (2015-16 through 2024-25) and qualifies as an LTR.5

Position from 6 April 2025. The trust loses excluded property status because the settlor is now an LTR at the date of the first chargeable event under the new regime.167 The foreign settled property enters the relevant property regime and becomes subject to periodic and exit charges.

Transitional protection. The trust was settled before 30 October 2024 and held excluded property at that date. The GWR exemption applies: if Settlor A remains a beneficiary and dies as an LTR, the foreign property is disregarded for GWR purposes provided it remains foreign-situs and settled at death.21 However, the trust is subject to periodic charges of up to 6% at each 10-year anniversary, capped at GBP 5 million per cycle under section 75B.23 At the first 10-year anniversary after the regime change (2020, being 10 years from the 2010 settlement, would have occurred pre-regime; the next falls in 2030), the charge is calculated reflecting only the complete quarters from 6 April 2025 to the anniversary date, with the effective rate adjusted for the period of excluded property status prior to that date.226

If Settlor A subsequently leaves the UK and becomes non-UK tax resident for the required consecutive years (3 years, given 10 prior years of residence within the 20-year window), LTR status expires.5 The trust regains excluded property status, but the transition out of the relevant property regime triggers a proportionate exit charge under section 65.1819

5.4 Forthcoming Complexity: Pension Death Benefits

From 6 April 2027, most unused pension funds and pension death benefits will be brought within the value of a person's estate for Inheritance Tax purposes.28 This represents a significant expansion of the IHT estate: pension assets that were previously outside IHT scope will, for the first time, form part of the deceased member's taxable estate. Death in service benefits payable from registered pension schemes and dependants' scheme pensions from defined benefit arrangements are excluded from this change, and existing spousal and charity exemptions are preserved.28 For international clients with cross-border pension arrangements, the interaction between the pension IHT charge and the excluded property framework will require careful analysis -- particularly where pension assets are held in overseas schemes or where beneficiaries are not LTR. Personal representatives, rather than pension scheme administrators, will bear liability for reporting and paying any IHT due on the affected pension assets.28 Practitioners should monitor HMRC implementation guidance as the April 2027 commencement date approaches.

Conclusion

The Finance Act 2025 has effected a fundamental reconception of excluded property within the UK Inheritance Tax framework. The shift from permanent, domicile-based protection to a dynamic, residence-based test creates an advisory landscape characterised by continuous monitoring rather than one-time assessments. For foreign settled property, the repeal of section 48(3)-(3F) means that excluded property status is no longer fixed at settlement but fluctuates with the settlor's LTR status at each chargeable event -- a structural change that demands ongoing residence tracking by trustees and advisors alike. Transitional provisions offer partial mitigation for pre-30 October 2024 trusts through the GWR exemption and the GBP 5 million cap on relevant property charges, but these measures do not restore the comprehensive protection that the domicile-based regime provided. The inclusion of unused pension funds within the IHT estate from April 2027 will add a further layer of complexity to cross-border planning. International tax specialists must now maintain evidence-based residence records, reassess excluded property status at every chargeable event, and integrate the new compliance requirements -- IHT401a, D31a, and D31b schedules -- into their standard advisory processes.205

CPD Declaration

Learning Objectives

On completion of this article, international tax specialists should be able to:

  1. Identify the categories of excluded property under IHTA 1984 sections 6 and 48 as amended by Finance Act 2025, distinguishing those changed by the residence-based regime from those unchanged.
  2. Explain the dynamic exposure mechanism for foreign settled property, including how trust assets transition between excluded and non-excluded status as the settlor's LTR status changes at each chargeable event.
  3. Apply the QIIP dual-test requirement to determine when both settlor and life tenant LTR status must be assessed for excluded property purposes.
  4. Evaluate the scope and limitations of transitional protection for pre-30 October 2024 excluded property trusts, distinguishing the GWR exemption from the relevant property charge cap under section 75B.
  5. Assess when Schedule A1 anti-avoidance provisions prevent excluded property status for indirectly held UK residential property and the implications for offshore holding structures.

Reflective Questions

  • How would an international tax specialist adapt existing trust review procedures to incorporate the dynamic LTR monitoring obligation required under the post-April 2025 regime?
  • What information-sharing protocols should be established between offshore trustees and UK advisors to ensure timely determination of excluded property status at each chargeable event?
  • In what circumstances might the GBP 5 million cap under section 75B prove insufficient protection for large pre-30 October 2024 excluded property trusts, and what restructuring options merit consideration?

Estimated CPD Time

45-60 minutes (reading, reflection, and application to practice)

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 26 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. HMRC Inheritance Tax Manual, IHTM04271 -- Foreign settled property: introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04271 ↩ ↩2

  2. Brodies LLP, "Changes to excluded property trusts in 2025: a paradigm shift in UK inheritance taxation." https://brodies.com/insights/wills-and-estate-planning/changes-to-excluded-property-trusts-in-2025-a-paradigm-shift-in-uk-inheritance-taxation/ ↩ ↩2 ↩3

  3. Inheritance Tax Act 1984, section 6 (as amended by Finance Act 2025 s.44(3)). https://www.legislation.gov.uk/ukpga/1984/51/section/6 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  4. Finance Act 2025 (c.8), section 44. https://www.legislation.gov.uk/ukpga/2025/8/section/44 ↩ ↩2

  5. Inheritance Tax Act 1984, section 6A (inserted by Finance Act 2025 s.44(3)(4)). https://www.legislation.gov.uk/ukpga/1984/51/section/6A ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  6. ICAEW, "Changes to IHT from 6 April 2025." https://www.icaew.com/technical/tax/tax-faculty/taxline/articles/2025/changes-to-iht-from-6-april-2025 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  7. HMRC Inheritance Tax Manual, IHTM04273 -- Foreign settled property: the settlor's domicile. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04273 ↩ ↩2 ↩3 ↩4 ↩5

  8. HMRC Tax Receipts and National Insurance Contributions for the UK (monthly bulletin). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩

  9. Office for Budget Responsibility, Inheritance Tax Forecast. https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  10. GOV.UK, Inheritance Tax Thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  11. Price Bailey, IHT enquiry data obtained via Freedom of Information request (2025). https://www.pricebailey.co.uk/ ↩

  12. HMRC Inheritance Tax Manual, IHTM04262 -- Holdings in Open Ended Investment Companies (OEICs) and Authorised Unit Trusts (AUTs). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04262 ↩ ↩2

  13. Inheritance Tax Act 1984, section 48 (as amended by Finance Act 2025). https://www.legislation.gov.uk/ukpga/1984/51/section/48 ↩ ↩2 ↩3

  14. Inheritance Tax Act 1984, Schedule A1 -- Non-excluded overseas property. https://www.legislation.gov.uk/ukpga/1984/51/schedule/A1 ↩ ↩2 ↩3 ↩4

  15. HMRC Inheritance Tax Manual, IHTM04311 -- Finance (No 2) Act 2017 changes: UK residential property. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04311 ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  16. HMRC Inheritance Tax Manual, IHTM27220 -- Foreign property: property excluded from Inheritance Tax: foreign settled property. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm27220 ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  17. GOV.UK, Guidance on Inheritance Tax if you're a long-term UK resident. https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩2

  18. Inheritance Tax Act 1984, section 65 -- Charge at other times. https://www.legislation.gov.uk/ukpga/1984/51/section/65 ↩ ↩2 ↩3

  19. HMRC Inheritance Tax Manual, IHTM47023 -- Long-term UK residence test: Charges on 6 April 2025. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47023 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  20. HMRC Trusts and Estates Newsletter: April 2025. https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-april-2025 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  21. HMRC Inheritance Tax Manual, IHTM47060 -- Long-term UK residence test: Gifts with reservation of benefit. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47060 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  22. HMRC Inheritance Tax Manual, IHTM47022 -- Long-term UK residence test: Transitional provisions: Excluded property comprised in a settlement at 30 October 2024. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47022 ↩ ↩2 ↩3 ↩4 ↩5

  23. GOV.UK, Capping Inheritance Tax trust charges for excluded property in trusts at 30 October 2024. https://www.gov.uk/government/publications/capping-inheritance-tax-trust-charges-for-former-non-uk-domicile-residents/cap-inheritance-tax-trust-charges-to-5m-for-former-non-uk-domiciles-from-6-april-2025 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  24. Saffery, "Inheritance tax reforms for UK non-doms." https://www.saffery.com/insights/articles/inheritance-tax-reforms-for-uk-non-doms/ ↩

  25. HMRC Inheritance Tax Manual, IHTM47021 -- Long-term UK residence test: Transitional provisions. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47021 ↩ ↩2

  26. Finance Act 2025 (c.8), Schedule 13 -- Inheritance Tax: long-term UK residence. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩ ↩2

  27. HMRC Inheritance Tax Manual, IHTM11033 -- Spouse or civil partner exemption: spouse or civil partner domiciled outside UK. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm11033 ↩

  28. GOV.UK, Inheritance Tax: unused pension funds and death benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3

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