The long-term residence test
GOV.UK describes a person as long-term UK resident where the statutory residence history test is met, broadly by reference to residence in at least 10 of the previous 20 tax years.
Detailed rules apply to age, years of residence and the period after departure.
Someone who has recently left may remain within the worldwide-property scope for a number of years. The length of that tail depends on prior residence, so the departure flight does not produce an immediate clean break.
UK assets remain important
UK-situated assets can remain within the UK Inheritance Tax framework regardless of long-term residence. UK homes, bank accounts, investments and company interests require an asset-by-asset review.
Debt location, deductibility, business relief and ownership structure are technical questions. Do not transfer an asset solely to change its location without considering Capital Gains Tax, income tax, Thai law and commercial control.
Business interests
Shares in a trading company may qualify for relief where the statutory conditions are met, while investment activities and excepted assets can limit relief. The company’s balance sheet and activity should be reviewed regularly rather than only after death.
A Thai company, UK company and cross-holdings may have different locations and succession procedures. Coordinate shareholder agreements, wills and company constitutions across both countries.
Wills and succession
A UK will may not deal efficiently with Thai assets or local probate requirements. Separate wills can help in some cases but must be drafted so that one does not revoke the other.
Review marriage, dependants, executors, digital assets, company authority after death and liquidity for tax. Thai inheritance and succession advice is needed alongside the UK analysis.
Planning evidence
- UK residence history for at least 20 years
- Asset and debt schedule by country
- Company trading and investment analysis
- Existing wills and beneficiary nominations
- Lifetime gifts and trusts
- Insurance and liquidity
- Expected duration of non-UK residence
Frequently asked questions
Does moving to Thailand immediately remove worldwide assets from UK Inheritance Tax?
No. The residence-based rules can keep a long-term UK resident within worldwide-property scope for a period after departure.
UK assets can remain relevant in any event.
Is domicile still the main test?
For deaths and other relevant events from 6 April 2025, the UK moved to a residence-based framework for this scope. Older domicile-focused guidance may not reflect the current law.
Do shares in my UK company automatically qualify for Business Relief?
No. The company and shares must satisfy the statutory conditions, and investment activity or excepted assets can restrict relief.
Obtain a current business-relief review.