Enter each period of UK tax residence as a date range. Leave "to" blank if the person is still UK resident. Any tax year (6 April to 5 April) touched by a period counts as a resident year, which matches HMRC's treatment of split years. You can correct any single year by clicking it on the ribbon below — useful where a departure or arrival year is not in fact a UK-resident year under the statutory residence test.

Decision flow for the long-term UK residence test

The chart follows the statute in the order a tribunal would read it: the basic ten-of-twenty condition in s.6A(1), the two exclusions in s.6A(2), the table in s.6A(3), and then the transitional relief in Finance Act 2025, Schedule 13, paragraph 46 that can remove long-term residence from someone who left the UK before 6 April 2025. The calculator's "statutory reasoning" list reproduces this flow for the facts entered. Every box cites the provision or HMRC manual paragraph it relies on.

Download the flowchart (SVG)

The elections route (top right) is shown for completeness: a person who would not otherwise be a long-term UK resident may elect to be treated as one, chiefly to unlock the full spouse exemption, at the price of bringing their own worldwide estate within UK inheritance tax for as long as the election has effect. See the Legislation tab, ss.267ZC–267ZE, and IHTM47031 onwards.

The statutory text

Reproduced verbatim from legislation.gov.uk (checked 15 September 2026). Sections 6A to 6C and 267ZC to 267ZF of the Inheritance Tax Act 1984 were inserted by the Finance Act 2025, section 44 and Schedule 13, with effect from 6 April 2025. Emphasis is not added. Contains public sector information licensed under the Open Government Licence v3.0.

Inheritance Tax Act 1984, section 6A — "Long-term UK resident": individuals

(1) For the purposes of this Act, an individual is a "long-term UK resident" at all times in a tax year if they were UK resident for at least 10 of the previous 20 tax years.

(2) But an individual is not a long-term UK resident at any time in a tax year ("the current tax year") if they were non-UK resident—

(a) for any 10 consecutive tax years during the 19 tax years before the current tax year, or

(b) for at least the required number of consecutive tax years ending with the tax year before the current tax year.

(3) To determine "the required number" for the purposes of subsection (2)(b), take the 20 tax years ending with the last tax year for which the individual was UK resident and find the number of those tax years for which the individual was UK resident ("the number of resident years").

The required number is the number in the second column of the following table corresponding to the number of resident years.

Number of resident years	Required number
13 or less	3
14	4
15	5
16	6
17	7
18	8
19	9
20	10

(4) In this section, "UK resident" means resident in the United Kingdom and "non-UK resident" means not resident in the United Kingdom.

(5) For the purposes of this section, a question as to whether the individual was UK resident for the tax year 2012-13 or an earlier tax year is to be determined as it would have been determined for income tax purposes for that tax year (and as to later tax years see Schedule 45 to the Finance Act 2013 (statutory residence test)).

(6) See also—

(a) section 6B (which modifies this section in its application to young persons);

(b) sections 267ZC to 267ZE (under which a person may be treated as a long-term UK resident as the result of an election).

Source: legislation.gov.uk/ukpga/1984/51/section/6A

Section 6B — "Long-term UK resident": young persons

(1) In the application of section 6A(1) for the purpose of determining whether a young person is a long-term UK resident at any time in a tax year ("the current tax year"), that subsection has effect as if—

(a) for "20" there were substituted the number of whole tax years for which the person was alive before the current tax year, and

(b) for "10" there were substituted half the number mentioned in paragraph (a) (rounded up, if not a whole number, to the next whole number).

(2) In subsection (1), "young person" means an individual who was under the age of 20 immediately before the current tax year.

(3) For the purposes of this Act, an individual is not a long-term UK resident at any time in a tax year if they were under the age of 1 (or were not yet born) immediately before the tax year.

Source: legislation.gov.uk/ukpga/1984/51/section/6B

Section 18 — Transfers between spouses or civil partners (as amended by FA 2025 Sch 13 para 6)

(1) A transfer of value is an exempt transfer to the extent that the value transferred is attributable to property which becomes comprised in the estate of the transferor's spouse or civil partner or, so far as the value transferred is not so attributable, to the extent that that estate is increased.

(2) If, immediately before the transfer, the transferor but not the transferor's spouse or civil partner is a long-term UK resident, the value in respect of which the transfer is exempt (calculated as a value on which no tax is chargeable) shall not exceed the exemption limit at the time of the transfer, less any amount previously taken into account for the purposes of the exemption conferred by this section.

(2A) For the purposes of subsection (2), the exemption limit is the amount shown in the second column of the first row of the Table in Schedule 1 (upper limit of portion of value charged at rate of nil per cent).

Subsection (2A) was inserted by FA 2013 s.178; the limit is currently £325,000. HMRC's view that the limit is cumulative across all spouses and civil partners is at IHTM11033 and IHTM47030. Source: legislation.gov.uk/ukpga/1984/51/section/18

Finance Act 2025, Schedule 13, paragraph 46 — Certain pre-commencement emigrants treated as not being long-term UK residents

46(1) An individual who would otherwise be a long-term UK resident at any time in a given tax year ("the relevant tax year") is treated for the purposes of IHTA 1984 as not being a long-term UK resident at that time if the individual—

(a) was not domiciled in the United Kingdom on 30 October 2024,

(b) has been resident in the United Kingdom for no tax year in the period beginning with the tax year 2025-26 and ending with the relevant tax year, and

(c) either—

(i) was resident in the United Kingdom for none of the 3 tax years immediately preceding the relevant tax year, or

(ii) was resident in the United Kingdom for fewer than 15 of the 20 tax years immediately preceding the relevant tax year.

(2) For the purposes of sub-paragraph (1)(a), in determining where an individual was domiciled on 30 October 2024, ignore section 267 (deemed domicile) and sections 267ZA and 267ZB (domicile elections) of IHTA 1984.

Source: legislation.gov.uk/ukpga/2025/8/schedule/13. Note: IHTM47020 Example 6 cites "IHTA84/S45(1)" for this rule; the operative provision is FA 2025 Sch 13 para 46.

Section 267ZC — Election to be treated as a long-term UK resident

(1) A person ("P") who would not otherwise be a long-term UK resident is treated as one for the purposes of this Act at any time when an election under this section has effect.

(2) An election under this section may be made—

(a) if condition A or B is met, by P;

(b) if condition B is met, by P's personal representatives.

(3) Condition A is that, at any time within the period of 7 years ending with the date on which the election is made, P had a spouse or civil partner who was a long-term UK resident.

(4) Condition B is that a person ("the deceased") dies and, at any time within the period of 7 years ending with the date of their death, the deceased was—

(a) a long-term UK resident, and

(b) the spouse or civil partner of P.

Section 267ZD — Further provision about elections under section 267ZC (extracts)

(1) An election under section 267ZC— (a) must be made by notice in writing to HMRC, and (b) has effect from such date as is, in accordance with subsection (2), specified in the notice.

(2) The date specified in a notice under subsection (1)(a) ("the specified date") must— (a) be after 5 April 2025, (b) be within the period of 7 years ending with— (i) in the case of a lifetime election, the date on which the election is made; (ii) in the case of a death election, the date of the deceased's death, and (c) meet the condition in subsection (3).

(4) A death election may only be made within— (a) the period of 2 years beginning with the date of the deceased's death, or (b) such longer period as an officer of Revenue and Customs may in the particular case allow.

(7) An election under section 267ZC cannot be revoked.

(8) If a person who made a lifetime election is, for a period of 10 successive tax years beginning after the date on which the election is made, not resident in the United Kingdom, the election ceases to have effect at the end of that period.

Section 267ZE — Subject of domicile election treated as a long-term UK resident

(1) This section applies where an election under section 267ZA has effect in relation to a person immediately before 6 April 2025 (whether the election was made before or after that date).

(2) The person is treated for the purposes of this Act (so far as would not otherwise be the case)— (a) as being a long-term UK resident, and (b) as having been one at all times on and after 6 April 2025.

(3) But if the person is not resident in the United Kingdom for a relevant lapse period beginning at any time after the election is made, subsection (2) ceases to apply to them at the end of that period.

(4) In subsection (3) "relevant lapse period" means— (a) if the election was made before 30 October 2024, a period of 4 successive tax years; (b) if the election was made on or after that date, a period of 10 successive tax years.

Sections 267ZC–267ZF inserted by FA 2025 Sch 13 para 27. Sections 267ZA and 267ZB (the former domicile elections) are repealed with effect from 6 April 2032 (Sch 13 para 45(2)). Source: legislation.gov.uk/ukpga/2025/8/schedule/13

Why this matters for pensions from 6 April 2027

Finance Act 2026 inserts section 150A into IHTA 1984, treating unused pension funds and death benefits ("notional pension property") as part of the deceased's estate for deaths on or after 6 April 2027. HMRC's Technical Note (updated 29 May 2026) explains at section 3.5 that a long-term UK resident is charged on notional pension property in registered pension schemes, qualifying non-UK pension schemes and section 615(3) schemes wherever established, while someone who is not a long-term UK resident is charged only on notional pension property in schemes established in the UK. HMRC's Technical Note 2 (27 August 2026) confirms that further guidance on international cases is to follow in a third note.

HMRC's published guidance

Extracts from the Inheritance Tax Manual, reproduced under the Open Government Licence v3.0. The manual is HMRC's interpretation and does not have the force of law; where it and the statute diverge, this calculator follows the statute and says so.

IHTM47020 — Long-term UK residence test (updated 7 April 2026)

From 6 April 2025, the test in IHTA84/S6A for whether foreign assets are in scope for Inheritance Tax will be whether an individual is a long-term UK resident, meaning they have been resident in the UK for at least 10 out of the last 20 tax years immediately preceding the tax year in which the chargeable event (including death) arises.

If an individual has been UK resident for at least 10 out of 20 years and then becomes non-resident and does not return to the UK before the chargeable event, there will be provision to shorten the length of time they remain a long-term UK resident if they had been UK resident for between 10 and 19 years out of the last 20.

For those who are resident between 10 and 13 years, they will remain in scope for the minimum period of 3 tax years. This will then increase by one tax year for each additional year of residence up to a maximum of 10 tax years.

For those not resident at the date of the chargeable event (including death) where the years of non-residence are not consecutive, the test at IHTA84/S6A(2) is applied and the individual will remain a long-term UK resident until the required number of years of consecutive non-UK residence has passed (IHTA/S6(3)).

An individual will not be treated as long-term UK resident for Inheritance Tax purposes in the year following 10 consecutive years of non-residence, even if they return to the UK; the test is effectively reset. This aligns with the 10 consecutive years of non-residence required to access the 4-year Foreign Income and Gains (FIG) regime.

The long-term UK residence test applies regardless of an individual's common law domicile.

Whether an individual is resident in a tax year will be as determined for the purposes of Income Tax and Capital Gains Tax (CGT). The Statutory Residence Test ("SRT") (RFIG20000) applies for 2013 to 2014 onwards. For tax years prior to 6 April 2013 the pre-SRT rules will apply (RFIG30000). Where an individual has split year treatment under the SRT this will count as a full year of UK residence for Inheritance Tax purposes.

Source: gov.uk — IHTM47020. Each of these examples is available from the "Load a worked example" menu on the Calculator tab and the engine reproduces HMRC's stated outcome in every case.

IHTM47021 — Transitional provisions

There are transitional provisions for non-domiciled or deemed domiciled individuals who are non-UK resident in 2025-26. For those individuals, they will be long-term UK resident if they satisfy the existing deemed domicile test, namely whether they have been resident for at least 15 out of the 20 tax years immediately preceding the year of charge, and for at least one of the four tax years ending with the relevant tax year. If they become UK resident again in 2026-27 or after, the new long-term UK residence rules will apply to them.

This transitional provision will not apply to individuals who are UK domiciled under common law on 30 October 2024 and the new long-term UK residence test will apply to them from 6 April 2025.

This means that: An individual who is not domiciled or deemed domiciled in the UK on 30 October 2024 who becomes non-resident in 2025-26 will not be a long-term UK resident (however, if they return to the UK the usual long-term UK residence test will apply). An individual who is deemed domiciled in the UK on 30 October 2024 who becomes non-resident in 2025-26 will be a long-term UK resident until the start of their fourth year of non-residence (however, if they return to the UK the usual long-term UK residence test will apply).

Source: gov.uk — IHTM47021

Where the UK-born emigrant stands

Other manual paragraphs referred to

IHTM47024 (young persons, s.6B); IHTM47030 (spouse or civil partner exemption where the survivor is not a long-term UK resident); IHTM47031–47034 (spousal long-term UK residence elections: introduction, who can elect, when, and how); IHTM47041 (domicile elections made before 6 April 2025 — transitional rules); IHTM11033 (the cumulative nature of the s.18(2) limit). Residence itself: RFIG20000 (statutory residence test) and RFIG30000 (pre-2013 rules).

How the calculator works

For the tax year containing the assessment date (and for each of the twelve tax years that follow it), the engine applies the statute in this order and records each step:

1. If an election under s.267ZC (or a saved domicile election under s.267ZE) is marked as in effect, the person is treated as a long-term UK resident and no further test is run.
2. If a date of birth is given and the person was under 20 immediately before the tax year, the s.6B substitution is made: the look-back becomes the number of whole tax years alive, and the threshold half that number rounded up. Under 1 (or unborn) is never a long-term UK resident.
3. The s.6A(1) count: resident years in the 20 tax years immediately before the current year. Fewer than 10 means not a long-term UK resident, and the engine stops.
4. The s.6A(2)(a) reset: any run of 10 consecutive non-resident years within the 19 years before the current year excludes the person, even where the ten-of-twenty count is met.
5. The s.6A(2)(b) tail: if the person was non-resident in the year before the current year, the engine finds the last resident year L, counts resident years in the 20 tax years ending with L, reads the required number from the s.6A(3) table, and compares it with the run of non-resident years ending with the year before the current year. The tail ends on 6 April of tax year (L + 1 + required number).
6. The paragraph 46 relief: if the person is marked as not UK-domiciled under common law on 30 October 2024, and has not been UK resident in any year from 2025-26 to the current year, and either was resident in none of the three preceding years or in fewer than 15 of the twenty preceding years, they are treated as not a long-term UK resident notwithstanding steps 3 to 5.

For a couple, both individuals are assessed for each year and the s.18 position is read off for each direction of transfer: the exemption is limited to the nil-rate band only where the transferor is a long-term UK resident and the survivor is not (s.18(2)); in every other combination it is unlimited (s.18(1)).

The engine was tested against the six worked examples in IHTM47020 and the three in IHTM47021 and reproduces HMRC's stated outcome in each. Where the manual's prose is looser than the statute — for example, the Dexter example assumes the ten qualifying years fall inside the look-back window — the engine follows the statute.

What the calculator does not do

• It does not decide residence. Whether a person was UK resident for a given tax year is a question under the statutory residence test (FA 2013 Sch 45) for 2013-14 onwards and under the earlier case-law-based rules before that. The calculator takes the years as entered. Departure and arrival years in particular should be checked: a split year counts as a full resident year, but a year in which the person fails every SRT test is not a resident year even if they were in the UK for part of it. Click the year on the ribbon to correct it.
• Domicile on 30 October 2024 must be judged under common law, ignoring deemed domicile and domicile elections (Sch 13 para 46(2)). A UK-born person who has lived abroad for decades may have acquired a domicile of choice, but the burden of showing it is heavy; do not tick the box without advice.
• Estate-tax treaties. The UK's conventions with India, Pakistan, France and Italy still operate by reference to domicile (see s.267ZF). They are outside this tool. The UK–Australia Double Taxation Convention does not cover inheritance tax at all.
• Elections are shown as an on/off assumption. The conditions in s.267ZC (a long-term UK resident spouse within the previous seven years; death elections within two years of death) and the lapse rule in s.267ZD(8) are described in the commentary but are not modelled year by year.
• Scope of assets is described in outline only. Which pension arrangements fall within section 150A, how an Australian superannuation fund is characterised, and what happens on a death during the tail are for HMRC's forthcoming Technical Note 3 and for advice on the facts.
• Nothing here is advice. It is a working aid for professional advisers and their clients, prepared by Expert Pensions Advice LLP, authorised and regulated by the Financial Conduct Authority (FRN 746548). Nothing is stored on any server; a scenario link simply encodes the entries in the address.

Sources checked

• Inheritance Tax Act 1984 ss.6, 6A, 6B, 18, 150A, 267ZC–267ZF — legislation.gov.uk, revised text, 15 September 2026.
• Finance Act 2025 s.44 and Schedule 13 (Parts 1 and 2) — legislation.gov.uk, as enacted.
• Finance Act 2026 (Royal Assent 18 March 2026) — s.150A and Schedule 12 as described in HMRC's Technical Note.
• HMRC Inheritance Tax Manual IHTM47000 series (IHTM47020 updated 7 April 2026; IHTM47021, 47024, 47030–47034, 47041).
• HMRC, "Technical note: Inheritance Tax on pensions" (updated 29 May 2026) and "Technical note 2: Further information on Inheritance Tax and pensions" (27 August 2026).
• The Inheritance Tax (Information Sharing Regulations) 2026, SI 2026/818.

Version 1.0 — 15 September 2026. Corrections and suggestions to Expert Pensions Advice LLP.