UK inheritance tax for expatriates: the questions that changed

Your address is only one part of the family picture

You may live abroad while retaining UK pensions, property and beneficiaries. Start with how those assets support your life and how they should pass on, then put inheritance tax into that wider plan.

Leaving a country and leaving its estate-tax system are not always the same event

For internationally mobile families, residence, asset location, ownership, succession and timing can all move at different speeds. The practical task is to map those moving parts before assuming that a flight, visa or new home automatically changes the whole estate position.

The 10-out-of-20 framework

HMRC states that a person can be a long-term UK resident if they were UK tax resident for at least 10 of the previous 20 tax years. Where that status applies, overseas assets may also come within the UK inheritance-tax framework.

Leaving the UK may not end exposure immediately

Depending on previous UK residence, long-term residence can continue for a period after departure. HMRC describes a tail that can run from a minimum of three tax years up to ten years. Transitional rules can also matter.

UK assets can still matter when you live abroad

Even where worldwide assets are outside the UK inheritance-tax net, UK-situated assets can remain relevant. Property, ownership structures, trusts, gifts, pensions, life cover and the location or legal ownership of investments may all require separate analysis.

Why ownership structure matters

Two portfolios with the same investments can have different legal ownership. Some international arrangements are contracts under which a financial institution or insurer holds underlying assets while the individual owns contractual rights. That can change administration, succession and tax questions, but it is not automatically advantageous and requires jurisdiction-specific tax and legal review.

• How many UK-resident tax years are in the last 20?
• When did you leave, and have you returned since?
• Which assets are still UK-situated?
• How are international investments legally owned?
• Are beneficiary nominations, wills and estate documents aligned across countries?
• Could liquidity be needed to settle an estate liability?

Pensions have a changing inheritance context

Finance Act 2026 brings most unused pension funds and pension death benefits into the inheritance-tax estate for deaths on or after 6 April 2027. Qualifying death-in-service benefits and other specified benefits are excluded. Residence, scheme location, beneficiaries and applicable exemptions matter; review the current HMRC technical notes for the specific arrangement.

A useful review starts with a family asset map

List the countries in which assets are held, how each is legally owned and who is intended to receive it. Include property, investment accounts, business interests and pensions without assuming they all follow the same rules. Put residence history alongside that list. This is preparation for advice, not a tax calculation.

Liquidity matters as well as value. A family may inherit valuable property but still need accessible money for administration, debts or tax. Wills, beneficiary arrangements, family needs and the interaction of different legal systems deserve attention together.

Keep tax within the whole financial life