Inheritance Tax Act 1984 section 267ZE

Subject of domicile election treated as a long-term UK resident

Section 267ZE deals with what happens to individuals who had a valid domicile election under the old rules (section 267ZA) immediately before 6 April 2025, and how they are transitioned into the new long-term UK resident framework for inheritance tax purposes.

• Anyone who had a valid domicile election in effect immediately before 6 April 2025 is automatically treated as a long-term UK resident from that date onwards.
• This deemed long-term UK resident status applies regardless of whether the original election was made before or after 6 April 2025, provided it had effect immediately before that date.
• The deemed status can lapse if the person ceases to be UK resident for a continuous period — either 4 tax years (for elections made before 30 October 2024) or 10 tax years (for elections made on or after 30 October 2024).
• Once the relevant lapse period of non-residence is completed, the person is no longer treated as a long-term UK resident under this provision.

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