Policy paper

Inheritance Tax: anti-avoidance measures for non-long-term UK residents and trusts

This tax information and impact note is about anti-avoidance measures to prevent use of situs of personal or trust property to avoid Inheritance Tax or pay less than long-term UK residents.

• From: HM Revenue & Customs
• Published: 26 November 2025

Documents

Inheritance tax: anti-avoidance

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Draft legislation — gifts to charities and registered clubs

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Draft legislation (accessible version)

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Draft legislation — provision relating to new regime

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Draft legislation (accessible version)

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Details

This measure will look-through non-UK companies or similar bodies to treat UK agricultural land and buildings as situated in the UK for inheritance tax purposes.
This measure also provides that where a settlor ceases to be a long-term UK resident, there will be an Inheritance Tax charge if there is a later change in situs of their trust assets.
Also, Inheritance Tax charity exemption will be restricted to gifts made directly to UK charities and registered clubs, and excluded from gifts to trusts which are not registered as UK charities or clubs.

Published 26 November 2025