IHTM43042 - Domicile/long term residence: calculation where domicile/long term residence of first spouse or civil partner to die is outside the UK
Every person, whether听or not听long-term UK resident听(IHTM47000)听or听UK domiciled听(IHTM13000), is entitled to the full nil rate band to be set against their estate that is subject to Inheritance Tax (IHT).听
The availability of transferable nil听rate band (TNRB) (IHTM43000)听from听the estate of the first to die of听a non long-term听UK resident,听or non-UK听domiciled听spouse or civil partner,听is calculated only by reference to property that is potentially subject to an UK IHT charge. For a spouse or civil partner who was not听a long-term听UK resident听on or after 6 April 2025, or听non-domiciled听before that听date,바카라 사이트�VT바카라 사이트�(IHTM43020) will be calculated only by reference to their estate in the UK. Assets held outside the UK, by a person not domiciled, or deemed听domiciled听in the UK听(before听听6听April 2025)听or听not听a听long-term听UK听resident听(from听6听April听2025), regardless of the devolution of those assets,听are not taken into account听when calculating the available unused nil听rate band.听
Thus,听where the survivor dies in the UK and their spouse or civil partner, who held no UK assets, died domiciled听abroad/not a long term听UK resident听leaving听all their overseas assets to their children, none of the nil听rate band was used on the first death. The personal representatives of the survivor may claim to transfer 100% of the nil听rate band to the estate of the survivor.听
Example听
Abdul was domiciled听abroad听(before 6 April 2025). His only asset situated in the UK was a US dollar account containing听US$250,000. He left this and the remainder听of his estate to his son, Jamil who lives in the UK.바카라 사이트� After the death, his wife, Soroya, moved to the UK to live with Jamil and听died as a听long-term resident听in the UK听(on or after 6 April 2025).听
础产诲耻濒바카라 사이트檚听assets situated outside the UK are not liable to IHT. The US dollar account is left out of account (IHTM04380) in determining听础产诲耻濒바카라 사이트檚 estate at death. So,听although the whole estate passed to Jamil, no property was chargeable to IHT, leaving the nil听rate available for transfer in full on Soroya바카라 사이트檚 death.