The UK government confirmed in its Autumn Budget on 30 October
2024 that, from 6 April 2025, it is to replace 'domicile'
as a connecting factor for liability to applicable UK taxes,
including inheritance tax (IHT), and adopt a residence-based regime
instead.
Accordingly, as from 6 April 2025, individuals who have been UK
resident for at least 10 out of the past 20 tax years – for
example, a person who was UK resident for 11 tax years from 6 April
2014 to 5 April 2024 – will be classified as a 'long-term
resident' (LTR) and exposed to IHT on their worldwide assets.
Once an individual gains LTR status it will generally take 10 tax
years of non-UK residence to lose it.
At the same time, the status of trusts established by non-UK
domiciled individuals with non-UK (overseas) assets –
generally termed as 'Excluded Property Trusts' (EPTs) for
IHT purposes – will no longer reflect the domicile status of
the settlor when the trust was established or when assets
