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Probate and inheritance tax for expats and UK domicile.

Cross-border estates are where confident generalisations go to die, so treat everything here as a starting point rather than an answer. The UK rewrote the foundations in April 2025: inheritance tax exposure now turns on long-term residence, not the old concept of domicile.

10 of 20
Years of UK residence that trigger worldwide exposure
Apr 2025
Domicile replaced by long-term residence

What makes expats accounting different.

The 10-in-20 test

If you have been UK resident for at least 10 of the last 20 tax years, your worldwide assets fall within UK inheritance tax; and after you leave the UK, that worldwide exposure can continue for a tail of several years, longer for those who were resident for longer.

UK assets still count if you are not a long-term resident

If you are not a long-term UK resident, UK inheritance tax generally reaches only your UK assets, such as UK property and, in many cases, UK company shares. UK residential property is caught even when held through offshore structures.

Other countries have their own rules

The country where you live, or where your assets sit, may impose its own inheritance or succession taxes, and some countries have forced heirship rules that constrain who can inherit regardless of your will.

Coordinating wills across countries

A single UK will can be valid for foreign assets, but it is often safer to have coordinated wills in each relevant country, drafted so that neither accidentally revokes the other.

What we do for expats.

Size your UK exposure

Use our calculator to size your UK exposure under the current rules.

First pass on the residence test

The residence self-check gives a first pass on the 10-in-20 test.

A specialist in cross-border estates

Cross-border estates are specialist work, and we can connect you with a vetted firm that handles them.

Questions from expats

Does UK inheritance tax still depend on domicile?
No. The UK rewrote the foundations in April 2025. Inheritance tax exposure now turns on long-term residence rather than domicile. Broadly, if you have been UK resident for at least 10 of the last 20 tax years, your worldwide assets fall within UK inheritance tax.
What happens to UK inheritance tax exposure after I leave the UK?
Worldwide exposure can continue for a tail of several years after you leave, longer for those who were UK resident for longer. If you are not a long-term UK resident, UK inheritance tax generally reaches only your UK assets, including UK residential property even when held through offshore structures.

Talk to a specialist about your situation

Book a free call. We will talk through your position and whether there is anything worth changing. No hard sell, no obligation.

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