Inheritance Tax
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Inheritance Tax Planning for Global Families
Inheritance tax is one of the few taxes you can plan for years in advance — and one of the most expensive to ignore. For internationally mobile families it has also just become considerably more complex: from 6 April 2025, the UK fundamentally changed how it decides who is exposed to inheritance tax, moving away from the old concept of domicile toward a system based on your history of UK residence.
If you are a British expat, or anyone with UK assets or a UK connection, the rules that applied even two years ago may no longer describe your position. NEBA Private Clients helps you understand where you now stand and plan to pass on your wealth efficiently and with certainty.
The big change: from domicile to residence
For decades, your UK inheritance tax exposure was driven by your domicile — broadly, where your permanent home was considered to be. That has changed.
Under the current rules, the key test is how long you have been UK tax resident:
- UK-situated assets (such as UK property) remain within the scope of UK inheritance tax for everyone, regardless of where you live.
- Non-UK assets generally come into the scope of UK inheritance tax once you have been UK tax resident for at least 10 of the previous 20 tax years — at which point you are treated as a “long-term resident”.
This is a significant shift, and it means many expats need to reassess a plan that was built around the old domicile rules.
The “tail” that catches people out
One feature of the new system surprises many people: leaving the UK does not switch off your exposure immediately. Depending on how long you were resident, UK inheritance tax can continue to apply to your worldwide estate for a number of years after you leave — often referred to as the inheritance tax “tail”.
For anyone planning to leave the UK, or who has recently done so, the timing of your departure and the length of your prior residence can materially affect your family’s eventual tax position. This is precisely the kind of thing that rewards early, specialist advice.
Why this is not a do-it-yourself area
UK inheritance tax interacts with the rules of every other country where you live or hold assets. Get it wrong and the cost falls not on you but on your family, after you are gone and unable to put it right. Common pitfalls include:
- Assuming that leaving the UK removes your exposure (the “tail” often means it does not).
- Overlooking that UK property remains taxable regardless of where you live.
- Misunderstanding the spouse exemption where spouses have different residence histories.
- Holding assets in structures designed for the old domicile-based rules.
These are not edge cases — they are the everyday situations internationally mobile families find themselves in. Professional, cross-border advice is essential.
How NEBA Private Clients helps
- We map your exposure under the current residence-based rules — across the UK and every jurisdiction relevant to you.
- We plan ahead — using legitimate, well-established strategies appropriate to your circumstances.
- We coordinate across borders — drawing on regulated permissions across the UAE, Singapore, Malaysia, South Africa and the UK, including FCA-regulated UK operations through our membership of TEAM plc.
- We keep it current — these rules change, and a plan must be reviewed as they do.
Frequently asked questions
Do expats pay UK inheritance tax?
It depends on your assets and your residence history. UK-situated assets (like UK property) are within scope for everyone. Your non-UK assets generally come into scope once you have been UK tax resident for at least 10 of the last 20 tax years.
Has domicile been abolished for inheritance tax?
The system has moved from a domicile-based test to a residence-based one from 6 April 2025. Domicile can still be relevant for certain historic positions and trusts, but residence is now the main connecting factor.
Does leaving the UK end my inheritance tax exposure?
Not immediately. Depending on how long you were resident, an inheritance tax “tail” can keep your worldwide estate within scope for several years after you leave.
Is UK property always subject to UK inheritance tax?
Yes — UK-situated assets remain within the scope of UK inheritance tax regardless of your residence status.
When should I get advice?
As early as possible, and certainly before leaving or returning to the UK, or making significant gifts or transfers. Early planning preserves the most options.
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The information on this page was correct at the time of publishing. Tax rules change, so please speak to an adviser to ensure you are working from the latest data.
