The shift from domicile to residence has fundamentally changed UK inheritance tax exposure for internationally mobile individuals. Here's what that actually means.

For decades, UK inheritance tax planning was built around domicile. A concept based on origin, intention and long-term connection, it gave internationally mobile individuals meaningful planning flexibility. That framework has changed.
From April 2025, the emphasis shifts to residence history. If you have been UK resident in at least 10 of the previous 20 tax years, your worldwide assets can come into scope for UK inheritance tax, both on lifetime transfers and on death. The test is measurable, rolling, and cumulative.
And it doesn't stop when you leave. Even after becoming non-resident, inheritance tax exposure can continue for years, depending on how much UK residence sits in your recent history. Many expats assume that departure ends worldwide exposure immediately. It often doesn't.
Shil Shah, Group Head of Tax Planning at Skybound Wealth Management, explains what has changed under the new regime, how the 10 out of 20 rule operates, what the IHT tail means in practice, and why the timing of gifts and restructuring is now more critical than ever.
Inheritance tax when you're young rarely feels urgent. But it is cumulative. Exposure builds quietly across years of residence history, and by the time it becomes obvious, the planning windows have often narrowed.
The move from domicile to residence is a structural shift, not a technical tweak. For expats, it changes exposure, timing and strategy. The right time to review is before departure, during non-residence, and before return. Not after the fact, when options are already limited.

Group Head of Tax Planning
Shil brings deep UK and international tax expertise to clients who live global lives. A Chartered Accountant and qualified financial planner, he spent nine years at Deloitte and KPMG before joining Skybound Wealth, where he leads the groupwide tax planning proposition across regions and borders.
Group Head of Tax Planning
Shil brings deep UK and international tax expertise to clients who live global lives. A Chartered Accountant and qualified financial planner, he spent nine years at Deloitte and KPMG before joining Skybound Wealth, where he leads the groupwide tax planning proposition across regions and borders.
Watch the full session free and find out where your inheritance tax exposure actually sits.
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