Double tax relief

Produced by Tolley in association with

Trusts and Inheritance Tax

Guidance

This guidance note is a summary of the information contained in the Double tax relief for IHT and Unilateral relief for IHT guidance notes. Those guidance notes provide more detailed information in the context of cross-border estates.

Double tax treaties

Where a double tax treaty has been entered into between the UK and a foreign territory, double tax relief for inheritance tax (IHT) will apply.

Where a double tax treaty applies, it should be considered in detail. Double tax treaties can be divided into those entered into before 1975 (estate duty treaties) and more recent treaties.

Domicile, deemed domicile and long-term UK residence

All of the UK tax treaties predate the concept of ‘deemed domicile’ which existed before 6 April 2025. Broadly, the post-1975 treaties refer to a person who is ‘UK domiciled for Inheritance Tax purposes’. This would include those who were deemed domiciled. The pre-1975 tax treaties rely on the concept of common law domicile and so these treaties did not apply to those who were deemed domiciled.

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