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Inheritance Tax Planning Strategies: Residence-Based Regime Essentials for Financial Advisors

· 18 min

Executive Summary

The Finance Act 2025 replaced domicile with long-term UK residence as the inheritance tax connecting factor from 6 April 2025, introducing a 10-out-of-20-year test that determines worldwide IHT exposure irrespective of common law domicile. Departing residents face graduated tail provisions of 3 to 10 years. Concurrently, nil-rate band and residence nil-rate band thresholds remain frozen until 2030-31, pension death benefits enter taxable estates from April 2027, and reformed agricultural and business property reliefs cap 100% relief at GBP 2.5 million from April 2026. IHT receipts reached GBP 6.6 billion in the first nine months of 2025-26, with Office for Budget Responsibility forecasts projecting GBP 9.1 billion for the full year. These converging reforms demand that financial advisors adopt integrated, multi-variable estate planning strategies rather than single-instrument approaches.

1. The New Connecting Factor: Long-Term UK Resident Test

From Domicile to Residence

The domicile-based IHT framework, rooted in common law principles of permanent home and succession, governed the scope of inheritance tax for over four decades. Its replacement by a residence-based test under Finance Act 2025, Part 2, Chapter 4 represents the most structurally significant change to IHT since the tax's introduction in 1986.1 The long-term UK resident (LTUR) test now applies a mechanical, year-counting methodology: an individual is an LTUR where they have been UK tax resident for at least 10 of the 20 tax years immediately preceding the tax year in which the chargeable event arises.2

Residence itself is determined by the Statutory Residence Test (SRT) established under Finance Act 2013, which employs automatic overseas and UK tests alongside a sufficient ties test. The interaction between the SRT and the LTUR test creates a two-stage determination process: first, whether the individual is UK tax resident in any given year; second, whether accumulated qualifying years meet the 10-out-of-20 threshold.3

Practical Implications of the Shift

The replacement of domicile with residence creates both greater certainty and expanded scope. Under the domicile framework, individuals who maintained a domicile of origin outside the UK -- or who successfully acquired a domicile of choice abroad -- could remain outside the worldwide IHT net regardless of the duration of their UK residence. The LTUR test eliminates this planning route entirely. Any individual who accumulates 10 qualifying years of UK tax residence within the relevant 20-year window is subject to IHT on worldwide assets, irrespective of where their common law domicile sits.4

For mainstream financial advisory practices, the shift affects three principal client segments. First, internationally mobile professionals who have resided in the UK for extended periods without acquiring a UK domicile of choice -- these clients may now find themselves within worldwide IHT scope for the first time. Second, returning UK nationals who had established a foreign domicile of choice -- prior planning predicated on domicile status requires immediate reassessment. Third, all long-standing UK residents whose estate plans were structured around domicile-based assumptions rather than residence-based analysis.5

HMRC guidance at IHTM47001 confirms that domicile retains limited relevance where existing double taxation conventions reference that concept, and in determining the applicable law of succession. However, for IHT scope purposes, the LTUR test is now determinative. The UK maintains IHT double taxation conventions with France, India, Ireland, Italy, the Netherlands, Pakistan, South Africa, Sweden, Switzerland, and the United States. Where these treaties reference domicile, the treaty provisions may override the domestic LTUR test for the specific assets and jurisdictions covered. Advisors managing clients with assets in treaty jurisdictions should obtain specialist cross-border tax advice to establish the interaction between treaty and domestic provisions.6

2. Tail Provisions and International Mobility Planning

The Graduated Tail Framework

Where an individual meets the LTUR test and subsequently becomes non-UK resident, continued worldwide IHT exposure does not cease immediately. The tail provision imposes a graduated period of ongoing liability, calibrated to the duration of prior UK residence.7 The structure operates as follows:

Prior UK Residence (within 20 years) Tail Duration
10-13 years 3 years
14 years 4 years
15 years 5 years
16 years 6 years
17 years 7 years
18 years 8 years
19 years 9 years
20 years 10 years

Each additional year of UK residence beyond 13 adds one year to the tail, up to a maximum of 10 years for individuals who were UK resident for the full 20-year period. During the tail period, the former LTUR remains within worldwide IHT scope -- death, lifetime chargeable transfers, and potentially exempt transfers during this window trigger the same IHT consequences as if the individual were still UK resident.8

The Clock Reset Mechanism

After 10 consecutive tax years of non-UK residence, the LTUR test resets entirely. The individual is no longer treated as an LTUR, even upon returning to the UK, and would need to accumulate 10 fresh qualifying years before re-entering worldwide IHT scope. This 10-year reset period aligns with the 10-year non-residence requirement for accessing the Foreign Income and Gains regime, providing a degree of structural coherence across the reformed tax framework.9

Transitional Provisions

Individuals who were not domiciled or deemed domiciled in the UK under common law on 30 October 2024 and who are non-UK resident from 2025-26 onwards benefit from transitional relief under Schedule 13 to the Finance Act 2025. They are not treated as LTUR provided they meet specific conditions: either non-resident for the 3 preceding tax years, or resident for fewer than 15 of the preceding 20 tax years. Spousal elections under the former section 267ZA, which were in effect immediately before 6 April 2025, continue but with defined sunset provisions -- ceasing after 4 successive tax years of non-UK residence for elections made before 30 October 2024, or 10 years for elections made on or after that date. Section 267ZA itself is repealed with effect from 6 April 2032.10

For advisors with internationally mobile clients, these transitional provisions create a narrow planning window. Clients who left the UK before 6 April 2025 and who meet the transitional criteria may benefit from reduced or eliminated LTUR tail exposure compared with clients who depart after the regime's commencement date. Advisors should conduct a priority review of any client who relocated internationally between 2022 and 2025, with particular attention to those whose UK residence history falls between 10 and 15 years -- the zone where transitional relief may apply.

Practical Scenario: The Internationally Mobile Professional

Consider a technology executive who arrived in the UK in 2012 and became UK tax resident from 2012-13. By 2025-26, this individual has accumulated 13 qualifying years of UK residence. Under the former domicile framework, if this executive maintained a non-UK domicile of origin and had never acquired a UK domicile of choice, worldwide assets remained outside the IHT net until the deemed domicile threshold was reached (15 out of 20 years). Under the LTUR test, this executive crossed the 10-year threshold in 2021-22 and is already fully within worldwide IHT scope. If the executive now relocates abroad, a 3-year tail applies. Only after 10 consecutive years of non-UK residence -- by 2035-36 at the earliest -- would the LTUR test reset entirely.

3. The Pension Paradigm Shift: April 2027 Inclusion

Policy Framework

From 6 April 2027, most unused pension funds and pension death benefits will be included within the value of a person's estate for IHT purposes. This measure, announced at Autumn Budget 2024 and confirmed following technical consultation, fundamentally alters the role of pensions within estate planning strategy.11

Under the current framework (pre-April 2027), unused defined contribution pension funds are generally outside the taxable estate for IHT. This treatment has made pension accumulation a significant estate planning tool -- particularly for wealthier clients who could afford to draw income from other sources while preserving pension wealth for intergenerational transfer. From April 2027, this advantage is substantially curtailed. The strategy of "spend other assets first, preserve pension wealth" -- widely advocated across the advisory profession since the pension freedoms of April 2015 -- requires fundamental reconsideration.

Liability and Reporting

A critical operational change accompanies the inclusion: personal representatives (PRs) -- not pension scheme administrators -- are liable for reporting and paying IHT attributable to pension wealth. PRs can direct scheme administrators to withhold up to 50% of taxable pension death benefits for up to 15 months from the date of death to cover anticipated IHT liability.12 This creates new coordination requirements between PRs, pension trustees, and beneficiaries that advisors must factor into estate administration planning.

The withholding mechanism introduces potential cashflow challenges for beneficiaries who may have anticipated immediate access to pension death benefits. Advisors should consider whether nomination forms and letters of wishes require updating to reflect the new IHT environment, and whether clients understand that pension beneficiaries may receive substantially less than the gross fund value after IHT deduction.

Death-in-service benefits paid from registered pension schemes and dependant's scheme pensions from defined benefit or collective money purchase arrangements are excluded from the IHT charge. Spouse and civil partner exemptions are preserved, as is the charity exemption for pension funds passing to qualifying charitable bodies.13

Scale of Impact

HMRC estimates that 10,500 estates will have new IHT liability in 2027-28 as a direct result of pension inclusion. A further 38,500 estates already within the IHT net are expected to pay additional IHT, with an average increase of approximately GBP 34,000 per estate. These figures are based on a projected 213,000 estates with inheritable pension wealth in the first year of operation.14

Time-Sensitive Planning Considerations

The April 2027 effective date creates a defined planning window of approximately 14 months from the date of this article. Advisors working with clients holding significant SIPP, SSAS, or other defined contribution pension wealth should evaluate drawdown acceleration strategies -- where clients can afford to draw pension income (taxed via income tax at their marginal rate) and deploy those funds into IHT-efficient vehicles such as normal expenditure out of income gifts under IHTA 1984 section 21, AIM-listed portfolio investment qualifying for BPR (subject to the reformed GBP 2.5 million cap), or whole-of-life insurance policies written into trust.

The trade-off between income tax on accelerated drawdown and IHT saved on death requires client-specific modelling. A client in the additional rate band (45%) would crystallise income tax at 45p per pound drawn, against a potential IHT saving of 40p per pound left in the pension at death. The arithmetic is not automatically favourable -- it depends on the client's income tax position, the expected date of death, growth assumptions, and whether the drawn funds can be deployed into immediately exempt transfers rather than remaining within the estate. For clients at basic or higher rate, or those who can establish section 21 gift patterns, the calculus shifts materially in favour of pre-April 2027 action.

4. Converging Reforms: Thresholds, Reliefs, and Anti-Avoidance

Frozen Thresholds and Fiscal Drag

The nil-rate band (NRB) at GBP 325,000 and the residence nil-rate band (RNRB) at GBP 175,000 have been frozen at 2020-21 levels. Finance Act 2025 extended the freeze to 2029-30, with Finance Bill 2025-26 proposing a further extension to 2030-31. CPI indexation is the legislative default from 2031-32 onwards.15 The RNRB taper threshold at GBP 2 million is also frozen, meaning estates exceeding that value lose GBP 1 of RNRB for every GBP 2 of value above the threshold -- a marginal effective IHT rate of 60% within the taper band.

In 2022-23, 31,500 estates (4.62% of UK deaths) were subject to IHT, generating GBP 6.70 billion in liabilities.16 While more than 90% of estates are forecast to have no IHT liability in each of the next five years, the absolute number of taxpaying estates continues to grow as asset values -- particularly residential property -- outpace the static thresholds. IHT receipts for April-December 2025 reached GBP 6.6 billion, a 4% increase on the equivalent period in 2024-25, and the OBR forecasts GBP 9.1 billion for full year 2025-26, rising to GBP 14.5 billion by 2030-31.17

Reformed Agricultural and Business Property Relief

From 6 April 2026, 100% APR and BPR are capped at a combined GBP 2.5 million allowance. Above this threshold, relief reduces to 50%, producing an effective 20% IHT rate on the excess. The allowance is transferable between spouses and civil partners, permitting up to GBP 5 million of qualifying property to pass at 100% relief for married couples. The GBP 2.5 million threshold remains fixed until 2030-31, with CPI indexation commencing from 2031-32. Interest-free 10-year instalment payments are available for qualifying property exceeding the allowance.18

This reform is particularly relevant for advisors working with business-owning clients and agricultural landholders. Estates with qualifying assets exceeding GBP 2.5 million face a new IHT charge that was previously entirely relieved. Up to 1,100 estates are expected to pay additional IHT in 2026-27 as a result.18 For a farming client with GBP 4 million of qualifying agricultural property, the IHT charge on the GBP 1.5 million excess -- at the effective 20% rate -- amounts to GBP 300,000, payable via interest-free instalments over 10 years.

Anti-Avoidance Provisions

Budget 2025 introduced three targeted anti-avoidance measures that constrain previously viable planning strategies.19 First, from 6 April 2026, UK agricultural property held via offshore structures is treated as UK-situated for IHT purposes, closing the "agricultural property look-through" route that certain non-domiciled landholders had employed to hold UK farmland outside the IHT net by interposing a non-UK company or partnership.

Second, from 26 November 2025, new subsections 8B and 8C to section 65 of IHTA 1984 impose exit charges on trust assets where trustees manipulate the situs of property to avoid IHT charges arising when a settlor ceases to be LTUR. Prior to this provision, trustees could relocate trust assets to non-UK situs before the settlor's departure from the UK, thereby avoiding the exit charge that would otherwise crystallise when excluded property status changed. The new provisions ensure that the charge applies by reference to the location of assets at the point of the LTUR status change, not at a later date.

Third, the IHT charity exemption is restricted to gifts made directly to UK-registered charities and community amateur sports clubs (CASCs), with lifetime gifts subject to this restriction from 26 November 2025 and death gifts from 6 April 2026. Estates that had planned charitable legacies to overseas charitable bodies -- including those in jurisdictions with which the UK previously recognised mutual charitable status -- must now review whether the intended recipient qualifies as a UK-registered charity or CASC.

These provisions directly affect advisors whose standard planning toolkit included offshore agricultural property structures, trust situs manipulation, or charitable giving routed through non-UK charitable entities. Each strategy requires reassessment against the post-Budget 2025 legislative framework.

5. Integrated Planning Framework for the Reformed Regime

Trust Implications

The residence-based regime fundamentally alters trust planning. From 6 April 2025, the excluded property status of non-UK assets within a trust is no longer determined by the settlor's domicile at the date of settlement but assessed dynamically against the settlor's LTUR status at the time of each IHT charge.20 When a settlor loses LTUR status, non-UK trust property becomes excluded property -- but an exit charge arises at that point. A transitional cap of GBP 5 million on relevant property IHT charges applies for trusts holding excluded property at 30 October 2024, but this protection does not extend to new additions made from that date or to newly created settlements.21

Advisors should review all existing trust arrangements where the settlor's IHT status has changed -- or will change -- under the new residence-based test. Structures that functioned effectively under domicile-based rules may produce unintended IHT consequences under the LTUR framework. In particular, trusts established by settlors who were non-UK domiciled but who are now LTUR will have lost their excluded property status, bringing non-UK assets within IHT scope at the next periodic or exit charge.

Client Segmentation and Prioritised Action

The convergence of these reforms creates differentiated urgency across client segments. Advisors may find the following triage framework useful in structuring client reviews:

Immediate priority (pre-April 2027): Clients with significant unused defined contribution pension funds who are likely to leave substantial pension wealth at death. These clients should evaluate accelerated drawdown and redeployment into IHT-efficient structures before pension inclusion takes effect.

High priority (pre-April 2026): Business owners and agricultural landholders with qualifying assets exceeding GBP 2.5 million. The reformed APR/BPR allowance creates a new IHT charge on previously relieved property, and succession planning structures may require adaptation.

Ongoing priority: Internationally mobile clients whose LTUR status -- or tail provision exposure -- requires monitoring against the 10-out-of-20-year test. Annual SRT assessment feeds directly into LTUR determination, making tax residence planning integral to IHT strategy.

Systemic review: All clients whose estate plans were constructed under domicile-based assumptions. The structural shift to residence-based IHT warrants a comprehensive estate planning audit, even where no immediate planning action is required.

Coordinating Lifetime Gifting with Other Strategies

Normal expenditure out of income gifts under IHTA 1984 section 21 remain one of the most effective IHT mitigation tools, and their importance increases as other reliefs are constrained. Section 21 exemption requires that gifts form part of the transferor's normal expenditure, are made out of income, and leave the transferor with sufficient income to maintain their usual standard of living. Unlike potentially exempt transfers, section 21 gifts are immediately exempt -- no seven-year survival period applies.22

For clients accelerating pension drawdown ahead of April 2027, the income generated can support section 21 gift programmes, effectively converting IHT-exposed pension wealth into immediately exempt lifetime transfers. This strategy requires careful documentation: HMRC expects evidence of a settled pattern of giving and demonstration that gifts are funded from surplus income rather than capital. Advisors should establish structured record-keeping frameworks for clients pursuing this approach, including annual income and expenditure statements, gift schedules, and evidence of regularity.

The Advisory Opportunity

The fiscal context underscores the scale of advisory opportunity. IHT receipts are projected to grow from GBP 9.1 billion in 2025-26 to GBP 14.5 billion by 2030-31 -- an approximately 59% increase over five years.23 Research from Downing indicates that 94% of advisors report rising IHT planning enquiries, with 76% reporting clients making surplus income gifts and 47% reporting clients reducing pension contributions in favour of IHT-focused solutions.24 Practices that develop integrated IHT advisory propositions -- combining pension strategy, lifetime gifting, trust planning, and investment structuring -- are positioned to capture substantial incremental revenue from a rapidly expanding market segment.

Conclusion

The residence-based IHT regime, pension death benefit inclusion, reformed APR/BPR allowances, frozen thresholds, and targeted anti-avoidance provisions collectively represent the most significant transformation of the UK inheritance tax landscape in a generation. The LTUR test provides greater mechanical certainty than the domicile framework it replaces, but simultaneously brings additional individuals within worldwide IHT scope. The April 2027 pension inclusion deadline creates a genuine time-sensitive planning window that warrants proactive client engagement. The reformed APR/BPR cap introduces new IHT charges for business and agricultural estates previously fully relieved, while anti-avoidance provisions curtail several established planning routes.

Financial advisors who treat these reforms as an interconnected system -- rather than addressing each in isolation -- will deliver materially better client outcomes. Integrated estate planning that coordinates pension drawdown strategy, lifetime gifting programmes, trust restructuring, and investment allocation across the reformed framework is no longer an optional enhancement to standard advisory practice. It is a professional imperative. The legislative landscape remains dynamic: Finance Bill 2025-26 is progressing through Parliament, and secondary legislation on pension IHT implementation will follow. Advisors should monitor HMRC guidance updates, particularly the Pensions Schemes Newsletter series and further technical amendments to the Finance Act 2025 residence-based provisions, to ensure advisory frameworks reflect the latest operational detail.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Estate Planning, Inheritance Tax, Pension Planning, International Tax

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Explain the long-term UK resident test mechanics and calculate tail provision duration for departing residents based on prior residence years (Understand/Apply)
  2. Evaluate the impact of pension death benefit IHT inclusion on drawdown strategies for clients with significant SIPP or SSAS holdings (Evaluate)
  3. Apply the reformed APR/BPR combined allowance of GBP 2.5 million to estate planning scenarios involving agricultural or business assets (Apply)
  4. Distinguish between planning strategies that remain viable under the post-Budget 2025 anti-avoidance provisions and those that have been curtailed (Analyse)
  5. Design an integrated estate planning review framework addressing the cumulative impact of concurrent IHT reforms across client segments (Create)

FCA Competency Mapping

  • COBS 9 -- Suitability: Assessing suitability of estate planning recommendations within the reformed IHT framework
  • TC 2.1 -- Technical Knowledge: Understanding of inheritance tax legislation and HMRC guidance as amended by Finance Act 2025
  • SYSC 5 -- Employees, agents and other relevant persons: Maintaining competence in rapidly evolving tax legislation

Reflective Questions

  1. How would you restructure your client review process to prioritise estates most affected by the concurrent IHT reforms discussed in this article?
  2. What additional documentation and record-keeping procedures would you implement to support clients pursuing accelerated pension drawdown combined with normal expenditure out of income gift programmes?
  3. How might the transition from domicile-based to residence-based IHT affect your firm's approach to advising internationally mobile clients, and what additional expertise or partnerships might be required?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Finance Act 2025, Part 2, Chapter 4 (March 2025). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩

  2. HMRC Inheritance Tax Manual, IHTM47020 -- Long-term UK residence test (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  3. GOV.UK -- Inheritance Tax if you're a long-term UK resident (April 2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩

  4. HM Treasury/HMRC Technical Note -- Reforming taxation of non-UK domiciled individuals (2024). https://www.gov.uk/government/publications/tax-changes-for-non-uk-domiciled-individuals/reforming-the-taxation-of-non-uk-domiciled-individuals ↩

  5. HMRC Inheritance Tax Manual, IHTM47001 -- Introduction and when domicile remains relevant (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47001 ↩

  6. HMRC Inheritance Tax Manual, IHTM47001 (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47001 ↩

  7. HMRC Inheritance Tax Manual, IHTM47020 (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  8. GOV.UK -- Inheritance Tax if you're a long-term UK resident (April 2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩

  9. HMRC Inheritance Tax Manual, IHTM47020 (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020; HaysMac -- Major changes to UK Inheritance Tax: the move to a residence-based regime from April 2025 (2025). https://haysmac.com/insights/major-changes-to-uk-inheritance-tax-the-move-to-a-residence-based-regime-from-april-2025/ ↩

  10. Finance Act 2025, Schedule 13 -- Transitional provisions (March 2025). https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩

  11. GOV.UK -- Inheritance Tax: unused pension funds and death benefits (October 2024, updated November 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  12. GOV.UK -- Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses (November 2025). https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩

  13. GOV.UK -- Reforming Inheritance Tax: unused pension funds and death benefits (November 2025). https://www.gov.uk/government/publications/reforming-inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-on-unused-pension-funds-and-death-benefits ↩

  14. GOV.UK -- Inheritance Tax: unused pension funds and death benefits (October 2024). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  15. GOV.UK -- Inheritance Tax nil-rate band and residence nil-rate band thresholds from 6 April 2026. https://www.gov.uk/government/publications/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026-to-5-april-2028 ↩

  16. GOV.UK -- Inheritance Tax liabilities statistics commentary (July 2024). https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩

  17. HMRC tax receipts monthly bulletin (January 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin; OBR Inheritance Tax forecasts. https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  18. GOV.UK -- Summary of reforms to agricultural property relief and business property relief (December 2025). https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩ ↩2

  19. GOV.UK -- IHT anti-avoidance measures for non-long-term UK residents and trusts (November 2025). https://www.gov.uk/government/publications/inheritance-tax-anti-avoidance-measures-for-non-long-term-uk-residents-and-trusts/inheritance-tax-anti-avoidance; Budget 2025 OOTLAR. https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar ↩

  20. HMRC Inheritance Tax Manual, IHTM47023 -- Charges on 6 April 2025 (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47023 ↩

  21. GOV.UK -- Capping Inheritance Tax trust charges for former non-UK domicile residents (October 2024). https://www.gov.uk/government/publications/capping-inheritance-tax-trust-charges-for-former-non-uk-domicile-residents/cap-inheritance-tax-trust-charges-to-5m-for-former-non-uk-domiciles-from-6-april-2025 ↩

  22. Inheritance Tax Act 1984, section 21 -- Normal expenditure out of income. https://www.legislation.gov.uk/ukpga/1984/51/section/21 ↩

  23. OBR -- Inheritance Tax forecasts in depth (November 2025). https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  24. Downing -- IHT Planning Research: Advisor Survey (2025). https://www.downing.co.uk/education-hub; Money Marketing -- IHT planning demand among advisors (2025). https://www.moneymarketing.co.uk/ ↩

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