IHTM13032 - Other domicile issues: domicile of life tenant/settlor and exclusion from charge to Inheritance Tax
From 6 April 2025, for inheritance tax purposes, domicile is replaced by long-term UK residence听补苍诲 you can find details of these rules 补迟听IHTM47000听补苍诲 IHTM47050.听
When considering foreign property in a settlement, whether fixed interest or discretionary before 6 April 2025, it is the domicile of the settlor(s) that determines whether the property is excluded from the charge to Inheritance Tax (IHT) (see IHTA84/S48 (3)(a) and IHTM27220).
Generally, the domicile of the life tenant (or class of beneficiaries) does not affect the IHT payable on foreign settled property (though their foreign free estate may be excluded property).