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Understanding offshore issues ― overview

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

Understanding offshore issues ― overview

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
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This sub-topic covers the fundamentals of offshore issues in the context of inheritance tax. Firstly it considers domicile ― the basis for charging inheritance tax up until 5 April 2025. After this date, the UK will move to a residence-based inheritance tax system and this is explained in a further guidance note. The deemed domicile rules are explained as well as the situs of assets and the concept of excluded property. Where a non-domiciled individual has an indirect interest in residential property, this will be chargeable to inheritance tax regardless of its situs and this sub-topic covers the rules in detail. Finally, an outline of the double tax relief rules for inheritance tax is provided which links to more detailed notes on the topic.

Domicile for UK inheritance tax

The

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