Inheritance Tax Act 1984 section 6C

"Long-term UK resident": bodies corporate

Section 6C defines when a body corporate (i.e. a company) is treated as a "long-term UK resident" for inheritance tax purposes, which determines whether its assets fall within the scope of IHT.

• A body corporate is a "long-term UK resident" for an entire tax year if it is incorporated in the United Kingdom.
• Alternatively, it qualifies if it was within the charge to corporation tax on income as a UK resident company at any time during the previous tax year.
• The test under the second limb relies on the company being chargeable to corporation tax by virtue of being UK resident under the Corporation Tax Act 2009.
• This provision took effect from 6 April 2025, introduced by Finance Act 2025.

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