UK inheritance tax reform April 2025: the long-term resident test explained
Knowledge Article · Inheritance & Estate Planning
UK April 2025 reform: what the long-term resident test means for everyone who has ever lived in the UK
The most significant UK IHT structural change in a generation. It replaced domicile with residency — and created departure tails that affect people who left years before the reform came into force.
From 6 April 2025, the United Kingdom abolished domicile as the primary basis for inheritance tax and replaced it with the Long-Term Resident (LTR) test. This is not a minor amendment — it fundamentally restructures who is within the UK IHT net, how exposure is calculated, and what happens when someone leaves the UK.
Principle 01 — The LTR threshold: 10 of 20 UK tax years
A person becomes a UK Long-Term Resident — and therefore subject to UK IHT on their worldwide estate — when they have been UK tax resident in at least 10 of the preceding 20 UK tax years. Once the threshold is crossed, worldwide IHT scope applies regardless of where the person currently lives.
The 20-year look-back window moves annually. As each new UK tax year begins, the earliest year in the window drops off. A person with exactly 10 qualifying years who has spent no further time in the UK will drop below the LTR threshold as the relevant years fall out of the window.
Principle 02 — The departure tail
When a UK LTR leaves the UK, their worldwide IHT exposure does not immediately end. A departure tail of between 3 and 10 years continues to apply, depending on total years of UK residence accumulated:
| Total qualifying UK years | Departure tail length |
|---|---|
| 10–13 years | 3 years |
| 14–16 years | 5 years |
| 17–19 years | 7 years |
| 20 or more years | 10 years |
A UK national with 25 years of UK residence who moved to Dubai in January 2024 carries a 10-year departure tail — worldwide UK IHT exposure until January 2034. Their UAE villa, UAE savings, and global portfolio are all within UK IHT scope until that date.
Principle 03 — Non-UK-domiciled individuals (formerly “non-doms”)
Prior to April 2025, non-UK-domiciled individuals were only subject to UK IHT on UK-situs assets — regardless of how long they had lived in the UK, subject only to the deemed-domicile rule (15 of 20 prior years). This provided a significant benefit for wealthy non-doms: long UK residence without worldwide UK IHT exposure.
From April 2025, this benefit is gone for long-term residents. A non-UK-domiciled individual who has been UK tax resident for 10 of the preceding 20 years is a UK LTR and faces worldwide UK IHT scope — the same as a UK national. The concept of domicile is now largely irrelevant to UK IHT for individuals.
Principle 04 — What has not changed
The UK IHT rate remains 40% above the nil-rate band (£325,000 for individuals; additional RNRB for qualifying residential property). The nil-rate band transferability between spouses remains. Business Property Relief (BPR) and Agricultural Property Relief (APR) remain available for qualifying assets. The spouse exemption remains — but only for UK-domiciled spouses (the spousal charge rules for non-UK-domiciled surviving spouses have been separately updated).
The most important action for anyone who has spent 10+ years in the UK: calculate your LTR status and departure tail length now — not when a death occurs. The departure tail calculation is based on facts existing at departure, not at death. Every year that passes without this calculation represents continued worldwide exposure that may be entirely unplanned.
Planning triggers — you should be reviewing this if…
- You are a UK national or former non-dom who left the UK in the past 10 years
- You moved to UAE, Spain, Portugal, Australia, France, or any other country from the UK in the past 10 years
- You had 10+ years of UK residence at any point and left after April 2015 (10-year look-back)
- You are a non-dom who was UK-resident for close to or more than 10 years before April 2025
- Your will was drafted before April 2025 by a UK solicitor who applied the domicile-based framework
- You received income tax relocation advice but no estate planning advice on departure
What this article cannot tell you
- Whether you are a UK LTR — requires calculating your specific qualifying year history under the SRT
- The exact length of your departure tail — depends on your specific residence history
- How transitional provisions apply to departures before April 2025
- Whether any bilateral estate tax treaty modifies your position
Frequently Asked Questions
What is the UK long-term resident test for inheritance tax?
From 6 April 2025, the UK Long-Term Resident (LTR) test replaced domicile as the primary basis for UK IHT. A person who has been UK tax resident in at least 10 of the preceding 20 UK tax years is a UK LTR and faces UK IHT on their worldwide estate at 40% above the nil-rate band (£325,000). This applies to UK nationals and foreign nationals alike.
I left the UK years ago — do I still have UK inheritance tax exposure?
Possibly yes. UK LTRs who leave the UK carry a departure tail of 3–10 years depending on total years of UK residence: 10–13 years = 3-year tail; 14–16 years = 5 years; 17–19 years = 7 years; 20+ years = 10-year tail. During the tail period, worldwide assets remain within UK IHT scope. If you had 15+ years of UK residence and left within the past 7 years, you are likely still within the tail.
Does the April 2025 UK IHT reform affect non-doms?
Yes, significantly. Before April 2025, non-UK-domiciled individuals with long UK residence were only subject to UK IHT on UK-situs assets (subject to the 15-of-20-year deemed domicile rule). From April 2025, a non-dom who has been UK tax resident for 10 of the preceding 20 years is a UK LTR — subject to worldwide UK IHT on the same basis as a UK national. The benefit of non-dom status for IHT purposes has effectively been eliminated for long-term UK residents.
What is the UK nil-rate band in 2026?
The standard nil-rate band (NRB) for UK IHT is £325,000 per individual, unchanged from previous years. An additional Residence Nil-Rate Band (RNRB) of £175,000 applies where a qualifying UK residential property passes to direct descendants. Between spouses, unused NRB can be transferred — giving a potential combined nil-rate amount of up to £1m for a married couple with qualifying residential property.
Does the UK LTR test affect UK nationals living in Spain, UAE, or Australia?
Yes. UK nationals with 10+ qualifying UK tax years who moved to Spain, UAE, Australia, or any other country carry the LTR departure tail. The tail length depends on total years of UK residence. A UK national with 20 years of UK residence who moved to Dubai in 2022 carries worldwide UK IHT exposure until approximately 2032. UAE’s nil-tax status provides zero relief against the UK departure tail.
FAQs are for general educational purposes only. Not legal, tax or financial advice.
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