For decades, UK inheritance tax exposure followed domicile, a concept tied to long-term intention rather than physical presence. From 6 April 2025 the UK moved to a residence-based test.
Under the new approach, an individual who has been UK tax resident for at least 10 of the previous 20 tax years falls within the scope of UK inheritance tax on their worldwide estate, regardless of their previous domicile position.
Exposure does not end on the day someone becomes non-resident. A tail period applies after departure, during which the worldwide estate remains within the UK inheritance tax net. The length of that tail depends on how long the individual was UK resident.
What this means in practice is that leaving the UK is a process with a timeline rather than a single event. The sequence and timing of a relocation matter, and both are questions for a licensed UK tax adviser.
A separate reform introduced a foreign income and gains regime for individuals arriving in the UK after a long period of non-residence. That regime concerns arrivals rather than departures and is outside the scope of this briefing.
Confirm your own position with a licensed UK tax adviser. Cyprus Gate does not advise on UK taxation.