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International Estate Planning: Tax Treaties and Double Taxation for UK Accountants

· 22 min

Executive Summary

The transition from domicile-based to residence-based Inheritance Tax from 6 April 2025 has exposed a structural gap between the modernised domestic framework and the UK's unreformed international treaty network. Ten bilateral IHT double taxation conventions -- the most recent signed in 1996, four predating 1975 -- now operate alongside the long-term UK resident test, with section 267ZF IHTA 1984 mapping LTR status to deemed domicile for treaty purposes. For the approximately 190 countries without any IHT treaty, unilateral relief under section 159 IHTA 1984 remains the sole mechanism. With IHT receipts reaching GBP 7.1 billion in the first ten months of 2025-26 and HMRC investigations increasing 41% year-on-year, accountants advising cross-border estates require a systematic framework for identifying double taxation exposure, selecting the correct relief mechanism, and managing procedural compliance under the new regime.

1. The Changed Landscape: Residence Replaces Domicile

1.1 The Long-Term UK Resident Test

The Finance Act 2025 (c.8), Schedule 13, enacted on 6 April 2025 the most fundamental restructuring of IHT's personal scope since capital transfer tax replaced estate duty in 1975.1 The long-term UK resident (LTR) test replaces deemed domicile as the gateway to worldwide IHT exposure. An individual is an LTR in a tax year if UK tax resident for at least 10 of the previous 20 tax years.2 The test applies regardless of common law domicile: a US citizen who has resided in the UK for a decade is within scope of IHT on worldwide assets, irrespective of any intention to return to the United States.23

For international estates, the consequences are immediate. Worldwide assets of LTRs fall within IHT scope, whilst non-UK assets of non-LTRs constitute excluded property.3 The nil-rate band remains frozen at GBP 325,000 and the residence nil-rate band at GBP 175,000 until at least April 2030-31, with the standard IHT rate at 40%.4

1.2 The IHT Tail: Continued Scope After Departure

When an LTR ceases UK residence, worldwide assets remain within IHT scope for a tail period determined by the length of prior UK residence:35

Years of UK Residence (of preceding 20) IHT Tail Duration
10-13 years 3 years
14 years 4 years
15 years 5 years
16 years 6 years
17 years 7 years
18 years 8 years
19 years 9 years
20 years 10 years

LTR status resets only after 10 consecutive years of non-UK residence.3 The tail creates double taxation scenarios absent under the former domicile-based system: an emigrating LTR who dies within the tail period faces potential IHT on worldwide assets whilst simultaneously subject to the destination country's equivalent death taxes or succession duties. The domestic IHT regime has been modernised, but the international relief framework has not.

1.3 The Enforcement Context

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 2024-25.6 The Office for Budget Responsibility forecasts GBP 14.5 billion by 2030-31, representing a 67% increase over five years.7 HMRC launched 3,961 IHT investigations in the year to April 2025, a 41% increase, indicating intensified compliance activity across all estate categories, including international estates.8 This revenue trajectory and enforcement posture demand that cross-border IHT exposure be managed with the same rigour applied to domestic estates.

2. The UK's Double Taxation Relief Framework

2.1 Two Statutory Mechanisms

UK law provides two distinct mechanisms for relief from international double taxation on IHT. Understanding both -- and their interaction -- is prerequisite to any cross-border estate analysis.

Section 158 IHTA 1984: Treaty-Based Relief. Section 158 authorises the Crown to make arrangements by Order in Council with foreign governments to afford relief from double taxation in respect of IHT and similar taxes charged on death or gifts inter vivos.9 Arrangements require House of Commons approval via draft resolution (s.158(4)), and pre-1975 Orders made under estate duty legislation remain valid and extend to IHT (s.158(6)).9 Information disclosure to foreign tax authorities is authorised under s.158(5).9

Section 159 IHTA 1984: Unilateral Relief. Section 159 provides a domestic relief mechanism available regardless of whether a treaty exists.10 Relief applies where overseas tax of "a character similar to that of inheritance tax" is imposed by any territory outside the United Kingdom on the same disposition or event (s.159(1)).10 This provision serves as the sole relief mechanism for estates involving assets in the approximately 190 countries with which the UK has no IHT double taxation convention.

Critically, section 159(7) provides that relief is given under whichever section -- 158 or 159 -- provides the greater benefit.10 Practitioners must therefore calculate relief under both provisions where a treaty exists, and apply the more favourable result. This "greater relief" rule is a statutory safeguard that prevents treaty provisions from inadvertently restricting relief below the level available unilaterally.

2.2 Situs Rules: The Foundation of Relief Eligibility

The situs (location) of property determines eligibility for relief under both treaty and unilateral mechanisms.11 HMRC guidance at IHTM27071 establishes a hierarchy: where a double taxation convention contains situs rules, those provisions take priority; otherwise, statute and case law determine situs.1112 UK-situs assets are always within scope of IHT regardless of LTR status or domicile.12

For cross-border estates, situs analysis requires particular care. Real property follows the jurisdiction where it is situated. Registered shares are generally sited where the share register is maintained. Bank accounts are sited where the branch is located. Debts are sited where the creditor resides. Intangible property, including goodwill, follows the domicile or residence of the owner -- a rule that produces different outcomes under the LTR framework compared to the former domicile-based system.

3. The Ten IHT Double Taxation Conventions

3.1 The Two-Tier Treaty Network

The UK maintains bilateral IHT conventions with ten countries, divisible into two distinct categories that operate under fundamentally different frameworks.1314

Post-1975 IHT-Era Conventions (Six)

Country Entry Date Coverage Key Features
Republic of Ireland 2 October 1978 Death and gifts Includes deemed domicile provisions
South Africa 6 May 1979 Death and gifts Estate duty and gift tax relief
United States 11 November 1979 Death and gifts Specific Form 742 certification procedures
Netherlands 16 June 1980 (amended 3 June 1996) Death and gifts Amended to include IHT; most recently updated
Sweden 19 June 1981 (amended 14 July 1989) Death and gifts Sweden abolished inheritance tax in 2004
Switzerland 7 March 1995 Estates, inheritances, and settlements Most recent convention; references deemed domicile under s.267 IHTA; covers property comprised in settlements but does not extend to outright gifts

Pre-1975 Estate Duty Treaties (Four)

Country Treaty Basis Critical Limitation
France Pre-1975 estate duty era No deemed domicile provisions
Italy Pre-1975 estate duty era No deemed domicile provisions
India Pre-1975 estate duty era No deemed domicile provisions
Pakistan Pre-1975 estate duty era No deemed domicile provisions

The pre-1975 treaties were negotiated under the Estate Duty Act and preserved under IHTA 1984 s.158(6).913 They do not contain provisions for deemed domicile, creating particular interpretive challenges under the LTR framework -- a point addressed in Section 3.3 below.

3.2 Section 267ZF: The Treaty Bridge

Section 267ZF of IHTA 1984, inserted by Finance Act 2025, Schedule 13, paragraph 27, provides the statutory mechanism for reconciling the LTR test with the domicile-based language of the existing treaty network.115 The provision directs that a person who is a long-term resident is to be treated as domiciled in the UK for the purposes of IHT where the application of a double taxation convention depends on domicile status. Subsection (3) carves out arrangements specified in Orders in Council made under s.158 before 17 July 2013 (other than by way of amendment on or after that date) from the LTR election provisions in ss.267ZC to 267ZE, and the section expressly does not affect the interpretation of pre-1975 arrangements preserved under s.158(6).1 The practical effect is to distinguish the six post-1975 IHT conventions -- all of which were enacted before 2013 -- from the four pre-1975 estate duty treaties, which retain their original interpretive framework.

The government has confirmed that the existing ten treaties will not be renegotiated.14 Section 267ZF is therefore the permanent interpretive bridge, not a transitional measure. HMRC guidance at IHTM47001 confirms that common law domicile retains relevance specifically "where there is an existing double taxation convention in operation between the UK and the relevant foreign country and its terms use the concept of common law domicile."16

This creates a layered analysis for practitioners. For post-1975 conventions, LTR status maps to deemed domicile via s.267ZF, and the treaty provisions apply on that basis. For pre-1975 treaties, the position is more complex: these conventions may continue to reference common law domicile without the benefit of a statutory mapping provision.

3.3 Pre-1975 Treaties: The Interpretive Challenge

The four pre-1975 estate duty treaties with France, Italy, India, and Pakistan present a distinct analytical framework.1314 These conventions predate the IHT regime entirely and lack deemed domicile provisions. Where an LTR dies owning assets in one of these jurisdictions, several questions arise that do not have settled answers.

First, does s.267ZF extend to pre-1975 treaties? The statute expressly provides that "nothing in this section affects the interpretation" of pre-1975 arrangements under s.158(6), indicating that the deemed domicile mapping does not apply to estate duty era treaties.1 The pre-1975 treaties therefore continue to operate on common law domicile concepts, creating a divergence between the domestic IHT charge (based on LTR status) and the treaty relief (based on domicile).

Second, where common law domicile remains relevant for treaty purposes, an LTR who is not common law domiciled in the UK may find that the pre-1975 treaty allocates taxing rights differently from the domestic LTR-based charge. An Indian national who has lived in the UK for 12 years, for example, may be an LTR with worldwide IHT exposure under domestic law, whilst the pre-1975 India treaty allocates relief on the basis of common law domicile in India.

For estates involving these jurisdictions, practitioners should consider the interaction between the treaty framework and the unilateral relief provisions under s.159, applying whichever provides greater benefit under s.159(7).10

3.4 The US-UK Estate Tax Convention

The US-UK Estate and Gift Tax Convention (1979) is the most commercially significant of the ten treaties given the volume of cross-border estates between the two jurisdictions.17 The convention operates on a credit method: primary taxing rights are allocated based on domicile (now LTR status via s.267ZF) and asset situs, with the non-primary jurisdiction providing credit for tax paid to the other.17

Key operational features for accountants include the following. Immovable property is taxed where situated regardless of LTR status or domicile.17 US citizens who are LTRs in the UK face both US estate tax (on worldwide assets above the applicable exclusion amount) and UK IHT (on worldwide assets as LTRs), with the treaty credit mechanism preventing full double taxation.17 The procedural dimension is particularly significant: Form IHT400 must include provisional double taxation relief amounts, but HMRC requires US Form 742 certification by the IRS before the IHT case can be closed (IHTM27170).18 IRS processing timescales for Form 742 can extend significantly, leaving the UK IHT return open and delaying the grant of probate.

3.5 The Lifetime Gifts Gap

A critical limitation across the treaty network concerns lifetime transfers. Most IHT double taxation conventions cover death transfers only and do not extend to potentially exempt transfers (PETs) or chargeable lifetime transfers (CLTs).1314 The US and Netherlands conventions do reference gifts in their titles and provisions, but the scope of relief for lifetime transfers should be verified on a treaty-by-treaty basis for any specific planning arrangement.

This gap creates material exposure. An LTR within the IHT tail who makes a cross-border gift may face UK IHT on that transfer (as a PET or CLT) whilst simultaneously triggering gift taxes or equivalent charges in the recipient's jurisdiction. Without treaty coverage for lifetime gifts, the sole relief mechanism is unilateral relief under s.159 -- and even this applies only where the overseas tax is "of a character similar to that of inheritance tax."10 Gift taxes that differ substantially in structure from IHT may not satisfy this condition, leaving a residual double taxation burden.

4. Unilateral Relief: The Default Mechanism

4.1 The Practical Reality

For the approximately 190 countries with which the UK has no IHT double taxation convention, section 159 IHTA 1984 is the sole mechanism for double taxation relief.10 In quantitative terms, unilateral relief applies to the vast majority of cross-border estates. Accountants advising clients with assets in Spain, Portugal, Germany, Australia, the United Arab Emirates, Canada, or any jurisdiction outside the ten treaty countries must rely entirely on s.159.

4.2 The Proportionate Relief Formula

Section 159 provides two relief calculations depending on the situs position of the relevant property.10

Full credit (s.159(2)): Where the property is situated only in the overseas territory, full credit is given for the overseas tax against the UK IHT attributable to that property.10

Proportionate credit (s.159(3)): Where the property is situated outside both jurisdictions or in both, the relief formula is:10

A / (A + B) x C

Where:

  • A = UK IHT attributable to the property
  • B = overseas tax attributable to the property
  • C = the lesser of A or B

Worked example -- Non-treaty jurisdiction (Spain): An LTR dies owning a Spanish property valued at GBP 400,000. UK IHT attributable to the property (after NRB apportionment) is GBP 80,000. Spanish succession tax (impuesto sobre sucesiones) imposed on the property is GBP 35,000. Since the property is situated only in Spain, full credit applies under s.159(2): the GBP 35,000 Spanish tax is credited in full against the GBP 80,000 UK IHT, reducing the UK liability to GBP 45,000.10

Worked example -- Proportionate credit: An LTR dies owning intangible assets (a business interest) with connections to both the UK and a non-treaty jurisdiction. UK IHT attributable: GBP 60,000 (A). Overseas tax: GBP 40,000 (B). The lesser of A or B is GBP 40,000 (C). Proportionate credit: 60,000 / (60,000 + 40,000) x 40,000 = GBP 24,000.10 The UK IHT liability reduces from GBP 60,000 to GBP 36,000. A residual combined burden of GBP 76,000 remains against GBP 100,000 of total tax -- the proportionate formula does not eliminate double taxation entirely.

4.3 Multi-Territory Aggregation

Where two or more overseas jurisdictions impose tax on the same disposition, sections 159(4) and 159(5) provide aggregation rules.10 The overseas taxes are combined for the purpose of calculating the proportionate credit, preventing relief from exceeding the UK IHT attributable to the relevant property. Practitioners handling estates with assets across multiple non-treaty jurisdictions -- a pattern increasingly common among internationally mobile LTRs -- must aggregate carefully rather than calculating relief on a jurisdiction-by-jurisdiction basis.

4.4 Evidence Requirements

Claiming unilateral relief requires evidence of overseas tax payment.10 Practitioners should obtain official tax assessments or certificates of payment from the overseas tax authority and retain these with the IHT400 submission. Where overseas tax remains unpaid at the time of the UK return, provisional relief claims may be included, but HMRC will not finalise the assessment until evidence of payment is provided.

5. The Practitioner Decision Framework

Accountants assessing cross-border estates under the post-April 2025 regime should apply the following structured approach.

Step 1: Determine LTR Status and IHT Tail Position. Establish whether the deceased (or donor, for lifetime transfers) was an LTR at the relevant date by applying the 10-of-20 year test.2 If the individual had ceased UK residence, calculate the remaining tail period. If the individual had been non-UK resident for 10 consecutive years, LTR status has reset and worldwide assets are outside IHT scope (non-UK assets are excluded property).3

Step 2: Identify All Jurisdictions with Taxable Assets. Conduct a comprehensive situs analysis for every asset in the estate, applying HMRC's situs hierarchy: treaty provisions (where applicable), statute, and case law.11 Map each asset to its jurisdictional situs and identify which jurisdictions impose death taxes or equivalent charges.

Step 3: Check for an Applicable Double Taxation Convention. For each jurisdiction identified in Step 2, determine whether one of the ten IHT DTCs applies.13 If so, identify whether it is a post-1975 convention (with s.267ZF mapping) or a pre-1975 estate duty treaty (with potential common law domicile considerations).16

Step 4: For DTC Jurisdictions -- Apply Treaty Provisions. Determine how the treaty allocates primary taxing rights and the credit mechanism available. Verify whether the treaty covers the specific transfer type (death transfer, lifetime gift). For US estates, initiate the Form 742 certification process with the IRS at the earliest opportunity given processing timescales.18

Step 5: For Non-DTC Jurisdictions -- Calculate Unilateral Relief. Apply the s.159 formula: full credit for overseas-situs property, proportionate credit for dual-situs or third-territory property.10 Aggregate where multiple non-treaty jurisdictions are involved.

Step 6: Compare Treaty and Unilateral Relief. Where a DTC exists, calculate relief under both the treaty provisions and s.159. Apply whichever provides the greater benefit under s.159(7).10 This comparison is mandatory, not discretionary.

Step 7: Assess the Spousal Exemption Position. Where the estate involves transfers between spouses of differing LTR status, apply the restricted spousal exemption rules. Transfers from an LTR to a non-LTR spouse are exempt only up to GBP 325,000 (the current nil-rate band).19 Transfers from a non-LTR to an LTR spouse remain fully exempt. Consider whether a spousal election to be treated as LTR -- which brings the electing spouse's worldwide assets within IHT scope -- is appropriate in the specific circumstances.19

Step 8: Review Trust Structures. For estates involving trust assets, determine whether excluded property trust transitional protection applies. Trusts settled and funded before 30 October 2024 by non-UK domiciled settlors benefit from partial transitional protection: foreign assets are not subject to gift with reservation rules, though relevant property regime charges still apply, capped at GBP 5 million per 10-year cycle.2021 New trusts settled after 30 October 2024 by LTR settlors enter the relevant property regime without transitional protection.21

5.1 Case Study: US Citizen LTR with Cross-Border Assets

A US citizen has been UK tax resident for 15 years. The individual dies owning a UK residential property (GBP 1.2 million), a US investment portfolio (GBP 800,000), and US real estate (GBP 500,000). The surviving spouse is a non-LTR US resident.

LTR status is confirmed (15 of previous 20 years). All worldwide assets are within UK IHT scope. The US-UK convention applies. Immovable property in the US is taxed by the US with credit against UK IHT. The US investment portfolio situs requires analysis under the treaty provisions. The spousal exemption is capped at GBP 325,000 for transfers to the non-LTR spouse.19 The treaty credit mechanism prevents full double taxation, but the restricted spousal exemption means that the IHT charge on assets exceeding GBP 325,000 passing to the surviving spouse is not exempt. Form 742 certification from the IRS is required before HMRC will close the IHT case.1718

5.2 Case Study: LTR with French Property and No Gift Treaty Coverage

A French national has been UK tax resident for 12 years and makes a GBP 300,000 gift to a French-resident child (a PET for UK IHT purposes). France imposes droits de donation on the gift. The pre-1975 France estate duty treaty covers death transfers only, not lifetime gifts.1314 Treaty relief is therefore unavailable. Unilateral relief under s.159 applies only if the French gift tax is "of a character similar to that of inheritance tax."10 French droits de donation may meet this threshold as a gratuitous transfer tax, but the characterisation requires careful analysis. If the donor dies within seven years, the PET becomes chargeable and the double taxation exposure crystallises without treaty protection.

6. Spousal Exemption in Cross-Border Marriages

The restricted spousal exemption for cross-border marriages is a material planning consideration that merits separate analysis beyond Step 7 of the decision framework.

From 6 April 2025, transfers from an LTR to a non-LTR spouse are exempt up to GBP 325,000 only.19 This cap mirrors the nil-rate band and applies cumulatively to lifetime transfers and death transfers combined. Transfers from a non-LTR to an LTR spouse remain fully exempt, as do transfers between spouses who are both LTRs.19

The non-LTR spouse may elect to be treated as an LTR for IHT purposes, removing the GBP 325,000 cap and securing full spousal exemption.19 However, the election brings the electing spouse's worldwide assets within IHT scope -- a potentially adverse consequence where that spouse holds significant overseas assets. The election lasts until 10 consecutive tax years of non-UK residence, providing an exit mechanism, but the decision requires careful modelling of the global tax position.19

The interaction with foreign succession law adds further complexity. In jurisdictions with forced heirship rules (including France, many civil law countries, and several Gulf states), the surviving spouse may not inherit the entire estate. Where forced heirship directs assets to children or other heirs, the UK spousal exemption does not apply to those non-spousal transfers, potentially increasing the UK IHT charge beyond what the client anticipated.

7. Procedural Requirements and Forward-Looking Considerations

7.1 IHT400 Reporting for International Estates

Form IHT400 is the principal inheritance tax account for international estates.22 Form IHT401 (Domicile outside UK) is required where the deceased was not UK domiciled or not an LTR, providing HMRC with the information needed to assess the scope of the IHT charge and the availability of excluded property treatment.22 Form IHT405 captures overseas property including houses, land, and buildings.22

Double taxation relief claims must be included in the IHT400 return. For treaty relief claims, practitioners should identify the applicable convention and the specific relief provisions relied upon. For unilateral relief claims, the s.159 calculation and supporting evidence of overseas tax payment must accompany the return.10 Where both treaty and unilateral relief are available, the return should include calculations under both methods with the greater relief applied.

7.2 Pension Death Benefits: The April 2027 Horizon

From April 2027, unused pension funds and pension death benefits will be included within the value of a member's estate for IHT purposes, with personal representatives liable for reporting and paying any resulting charge.23 For international estates, this introduces a further layer of cross-border complexity. LTRs with pension assets held across multiple jurisdictions will face potential double taxation on death benefits where the pension jurisdiction imposes its own charges and no IHT treaty covers pension assets specifically. Given that none of the existing ten treaties were drafted with pension death benefits in IHT scope, the interaction between treaty relief and pension death benefit taxation remains untested and should be monitored as HMRC develops operational guidance.

Conclusion

The post-April 2025 international IHT landscape presents accountants with a structural challenge: a modernised domestic framework operating alongside an unreformed treaty network that the government has confirmed will not be renegotiated. The ten bilateral conventions -- six post-1975, four pre-1975 -- provide incomplete coverage, and the s.267ZF mapping of LTR status to deemed domicile, while necessary, introduces interpretive complexity that will take years to resolve through practice and, potentially, case law.

The practical implications are clear. Unilateral relief under s.159 is the working reality for the majority of cross-border estates. The proportionate formula, while providing meaningful mitigation, does not eliminate double taxation entirely. The IHT tail creates new exposure scenarios for emigrating LTRs that did not exist under the domicile-based system. The restricted spousal exemption demands careful analysis in every cross-border marriage. And the pre-1975 treaties with France, Italy, India, and Pakistan require jurisdiction-specific expertise that goes beyond routine IHT compliance.

Accountants advising international estates should establish systematic processes for LTR status determination, situs analysis, treaty identification, and relief calculation -- applying the decision framework consistently rather than on an ad hoc basis. Where the cross-border dimension introduces uncertainty beyond the accountant's specialism, coordinated multi-jurisdictional advice from appropriately qualified professionals in each relevant jurisdiction is not merely prudent but essential to discharge the duty of care owed to the client.

CPD Declaration

Estimated Reading Time: 22 minutes Technical Level: Advanced Practice Areas: International Tax, Inheritance Tax, Cross-Border Estate Planning, Tax Compliance

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the two statutory mechanisms for double taxation relief on UK Inheritance Tax (IHTA 1984 ss.158 and 159) and their respective conditions for application
  2. Distinguish between post-1975 IHT conventions and pre-1975 estate duty treaties in terms of their treatment of deemed domicile, lifetime gifts, and the applicability of section 267ZF
  3. Apply the unilateral relief proportionate credit formula under s.159(3) to calculate relief for a cross-border estate involving non-treaty jurisdictions
  4. Evaluate the interaction between long-term UK resident status and the IHT tail provisions when advising emigrating clients on double taxation exposure
  5. Assess when a spousal election to be treated as LTR is beneficial versus disadvantageous for cross-border married clients with differing residence profiles

Competency Mapping

  • ICAEW Code of Ethics: Professional Competence and Due Care (Section 130) -- maintaining knowledge of cross-border IHT developments
  • CIOT/ATT Competency Framework: International Tax -- understanding double taxation relief mechanisms
  • AAT Professional Standards: Tax Compliance -- accurate completion of IHT400 returns for international estates

Reflective Questions

  1. How would the decision framework presented in this article change the approach taken when a client with assets in a non-treaty jurisdiction first presents for estate planning advice?
  2. What additional due diligence steps should be implemented when advising LTR clients within the IHT tail who are making cross-border lifetime gifts?
  3. In what circumstances would recommending a spousal election to be treated as LTR result in a worse overall tax outcome than accepting the GBP 325,000 cap on spousal exemption?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 24 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. Finance Act 2025 (c.8), Schedule 13 -- Inheritance Tax: long-term UK residence. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩ ↩2 ↩3 ↩4

  2. HMRC Inheritance Tax Manual, IHTM47020 -- Long-term UK residence test. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩ ↩2 ↩3

  3. GOV.UK, Inheritance Tax if you're a long-term UK resident (updated 6 April 2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩2 ↩3 ↩4 ↩5

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

  5. Royal London for Advisers, "LTR and Non-dom inheritance tax." https://adviser.royallondon.com/technical-central/protection-guidance/inheritance-tax-and-related-manuals/long-term-resident-and-inheritance-tax/ ↩

  6. HMRC Tax Receipts and National Insurance Contributions for the UK (monthly bulletin, February 2026). 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 ↩

  7. Office for Budget Responsibility, Inheritance Tax Forecast (Budget 2025). https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  8. HMRC Inheritance Tax Statistics Commentary. https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-statistics-commentary ↩

  9. Inheritance Tax Act 1984, section 158. https://www.legislation.gov.uk/ukpga/1984/51/section/158 ↩ ↩2 ↩3 ↩4

  10. Inheritance Tax Act 1984, section 159. https://www.legislation.gov.uk/ukpga/1984/51/section/159 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17

  11. HMRC Inheritance Tax Manual, IHTM27071 -- Foreign property: locality of assets (situs): introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm27071 ↩ ↩2 ↩3

  12. HMRC Inheritance Tax Manual, IHTM27000 -- Foreign property: contents. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm27000 ↩ ↩2

  13. GOV.UK, Inheritance Tax: Double Taxation Relief (updated 6 April 2025). https://www.gov.uk/guidance/inheritance-tax-double-taxation-relief ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  14. Laggan UK, "The UK's New Inheritance Tax System: The Shift to a Residence-Based Approach and the Role of Double Taxation Treaties." https://www.laggan-uk.com/the-uks-new-inheritance-tax-system-the-shift-to-a-residence-based-approach-and-the-role-of-double-taxation-treaties/ ↩ ↩2 ↩3 ↩4 ↩5

  15. GOV.UK, Technical amendments to the residence-based tax regime. https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩

  16. HMRC Inheritance Tax Manual, IHTM47001 -- Long-term UK residence test: Introduction and when domicile will remain relevant. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47001 ↩ ↩2

  17. The Double Taxation Relief (Taxes on Estates of Deceased Persons and on Gifts) (United States of America) Order 1979. https://www.legislation.gov.uk/uksi/1979/1454/made ↩ ↩2 ↩3 ↩4 ↩5

  18. HMRC Inheritance Tax Manual, IHTM27170 -- Foreign property: Double Taxation Conventions: USA. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm27170 ↩ ↩2 ↩3

  19. 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 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

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

  21. 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

  22. GOV.UK, Inheritance Tax Account (IHT400). https://www.gov.uk/government/publications/inheritance-tax-inheritance-tax-account-iht400 ↩ ↩2 ↩3

  23. GOV.UK, Inheritance Tax on unused pension funds and death benefits (April 2027 implementation). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

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