Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Inheritance tax definition

What does Inheritance tax mean? Inheritance tax describes the taxation of wealth transfers on death and, in defined cases, on lifetime gifts and trust transfers. In the UK (England & Wales, Scotland and Northern Ireland), Inheritance Tax is a statutory regime under the Inheritance Tax Act 1984, charged at rates up to 40% on transfers of value. It is usually payable from the deceased’s estate by personal representatives. Lifetime charges arise on chargeable lifetime transfers (typically gifts into most trusts) and where a donor dies within seven years of a potentially exempt transfer. Key features include the nil-rate band and, where conditions are met,...

Legacy UK tax planning for resident non-domiciliaries: remittance basis, excluded property trusts, deemed domicile, home ownership and offshore structures (to 5 April 2025) [Archived]

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Practice notes

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

The Finance Act 2025 (FA 2025), which gained Royal Assent on 20 March 2025, enacts the removal of the remittance basis of taxation and brings in a residence-based system commencing on 6 April 2025. FA 2025 also replaces domicile with residence as the key factor in establishing liability to Inheritance tax. Additional measures further revise the Rules for excluded property status, abolish the protected settlements status of offshore trusts, and amend overseas workday relief. For further detail and context, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

ARCHIVED: This Practice Note is archived and not maintained. It summarises the inheritance tax (IHT), income tax and Capital gains tax (CGT) regimes applying to UK-resident non-domiciliaries, and highlights the fundamental planning opportunities available to them. Such planning generally relates to the overseas assets and income of non-domiciliaries. To make use of the favourable rules, it should be confirmed at the outset that the individual is genuinely non-UK domiciled. The Henkes v HMRC case suggests...

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Stephen Parnham

Stephen has over 30 years experience helping individuals, owner managed businesses and trustees improve their tax positions. As well as advising his own clients, he provides professional technical support to firms of Chartered Accountants and Solicitors from Hampshire in the south to the West Midlands and Shropshire in the north.He brings clarity and direction to complex tax issues. He is a Chartered Tax Adviser ( CTA ), a Trust and Estate Practitioner ( TEP ) and a member of the Association of Taxation Technicians ( ATT ). He is a member of the Society of Expert Witnesses and regularly contributes to the professional press....

Web page updated on 21/05/2026

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