Inheritance Tax deemed domicile rules before 6 April 2025
Find out about the Inheritance Tax deemed domicile rules which applied from 6 April 2017 to 5 April 2025.
From 6 April 2025 the deemed domicile rules are replaced by the long-term UK resident rules.
Do not follow this guidance if your transfer of assets or the person’s death is on or after 6 April 2025, read Inheritance Tax if you’re a long-term UK resident.
Deemed domicile — number of years
From 6 April 2017 to 5 April 2025 you’re UK domiciled if you’re resident in the UK for 15 of the previous 20 tax years.
Before 6 April 2017 you were UK domiciled if you were resident in the UK for 17 of the previous 20 years.
You can still be UK domiciled if you leave the UK.
Formerly domiciled resident
From 6 April 2017 to 5 April 2025 there was another category of deemed domicile.
You’re a formerly domiciled resident if you:
- were born in the UK with a UK domicile of origin
- have acquired another non-UK domicile of choice
- are resident in the UK and were resident in the UK in at least one of the 2 previous tax years
If you’re a formerly domiciled resident, property you settled on trust when you were not domiciled in the UK is not excluded property for the purposes of Inheritance Tax. This does not apply if you’re only deemed domiciled.
The trust protection measures make sure there is no Inheritance Tax trust charge when you’re no longer:
- resident in the UK
- a formerly domiciled resident
Technical guidance and examples about these rules are in the Inheritance Tax manual.
Updates to this page
-
Inheritance Tax deemed domicile rules will no longer apply from 6 April 2025. From the 6 April 2025 you must follow the new long-term UK residence rules for Inheritance Tax.
-
A link to technical guidance and examples in the Inheritance Tax manual has been added.
-
First published.