Paragraph 46 Certain pre-commencement emigrants treated as not being long-term UK residents
United Kingdom
An individual who would otherwise be a long-term UK resident at any time in a given tax year (“the relevant tax year”) is treated for the purposes of IHTA 1984 as not being a long-term UK resident at that time if the individual—
was not domiciled in the United Kingdom on 30 October 2024,
has been resident in the United Kingdom for no tax year in the period beginning with the tax year 2025-26 and ending with the relevant tax year, and
either—
was resident in the United Kingdom for none of the 3 tax years immediately preceding the relevant tax year, or
was resident in the United Kingdom for fewer than 15 of the 20 tax years immediately preceding the relevant tax year.
For the purposes of sub-paragraph (1)(a), in determining where an individual was domiciled on 30 October 2024, ignore section 267 (deemed domicile) and sections 267ZA and 267ZB (domicile elections) of IHTA 1984.