IHTM13035 | Other domicile issues: Liaison arrangements with PTI Advisory and HMIT

From 6 April 2025, for inheritance tax purposes, domicile is replaced by long-term UK residence and you can find details of these rules at IHTM47000.

It is important that negotiation and agreement with a taxpayer about domicile and residence or ordinary residence does not prejudice the interests of the rest of HMRC, or run counter to any previous agreement between the taxpayer and HMRC.

If there is no note of any previous agreement or if the circumstances dictate that we need to investigate the question again, Technical will, if necessary, negotiate with PTI Advisory and/or HMIT before discussing or agreeing domicile or residence with the taxpayer.

You should note that Income Tax cannot be assessed more than three years after the date of death. So when a domicile outside the UK is claimed but not agreed for a taxpayer who was normally resident in the UK, PTI Advisory must be notified by us either:

• when a UK domicile is conceded by the taxpayer, or

• on the first BU date if the domicile has not been settled.

We must include:

• the name, address and date of death of the deceased,

• the names and addresses of the personal representatives,

• an indication of the likely value of the estate

• a brief note of the domicile position; and

• if known, the deceased’s tax office and UTR.