Inheritance Tax Act 1984 section 6A

"Long-term UK resident": individuals

Section 6A defines what it means to be a "long-term UK resident" for inheritance tax purposes, establishing the residence-based test that determines whether an individual's worldwide assets fall within the scope of IHT.

  • An individual is a long-term UK resident in a tax year if they were UK resident for at least 10 of the previous 20 tax years.
  • Long-term UK resident status can be lost after a sufficient period of consecutive non-UK residence, with the required period of absence depending on how many years the individual was previously UK resident.
  • The "tail" of IHT exposure after leaving the UK ranges from 3 years (for those resident 13 years or fewer out of 20) up to 10 years (for those resident all 20 years), creating a graduated exit from the IHT net.
  • Special rules apply to young persons (section 6B) and to individuals who elect to be treated as long-term UK residents (sections 267ZC to 267ZE).

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