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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Pre-owned assets: exemptions: foreign element - non-residence

The POA charge does not apply to a person for any year of assessment during which they are not resident in the UK, FA04/Sch15/Para12(1). Residence here has its normal meaning for income tax purposes.


David gave his son a sum of money in 2005 which is used to purchase a property for David to live in. David is liable to the POA charge from 6 April 2005; but he goes abroad on 1 May 2008 and remains there. David will be liable to the POA charge for 2005/06 and 2006/07, but he will not be liable in 2008/09 or later years unless his visits back to the UK result in him being treated as resident in the UK.

The position, should David return to the UK to live, is outlined at IHTM44012 (calculation of charge examples).