Inheritance Tax Act 1984 section 267ZF

Double taxation conventions operating by reference to deemed domicile

Section 267ZF explains how the concept of deemed domicile in the UK interacts with double taxation agreements for inheritance tax purposes.

• Where a double taxation agreement depends on whether someone is treated as UK-domiciled for inheritance tax, long-term UK residents are treated as UK-domiciled.
• For older double taxation agreements made before 17 July 2013 (and not subsequently amended), the voluntary election mechanism that allows certain individuals to opt into long-term UK resident status is disregarded.
• The section does not alter the interpretation of certain pre-1975 double taxation arrangements that were already in place before the modern inheritance tax regime began.
• This provision ensures that the new residence-based deemed domicile rules are properly reflected in the UK's international tax treaty obligations.

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