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Domicile for UK inheritance tax

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

Domicile for UK inheritance tax

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
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This guidance note discusses the concept of domicile and how this is key in assessing a taxpayer’s liability to inheritance tax. Domicile is a legal concept and there are three types of domicile ― origin, dependency and choice. This note explains how domicile is determined for IHT purposes and the evidence that will be needed to present to HMRC where a taxpayer claims non-domicile status. It covers the 2017 changes to the domicile rules including the introduction of the formerly domiciled residents rules and the possible changes from April 2025 that will remove domicile from the IHT regime, replacing it with a residence test.

The significance of domicile

Liability for UK inheritance tax depends on a person’s domicile. In contrast to other taxes such as income tax, capital gains tax and corporation tax, liability to IHT is not primarily determined by residence in the UK (although, a person’s domicile status may be informed by their residence status).

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