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Legislation
Inheritance Tax Act 1984

Crossheading Miscellaneous

  • Section 262 Tax chargeable in certain cases of future payments, etc.
  • Section 263 Annuity purchased in conjunction with life policy.
  • Section 264 Transfers reported late.
  • Section 265 Chargeable transfers affecting more than one property.
  • Section 266 More than one chargeable transfer on one day.
  • Section 267 Persons treated as domiciled in United Kingdom.
  • Section 267ZA Election to be treated as domiciled in United Kingdom
  • Section 267ZB Section 267ZA: further provision about election
  • Section 267ZC Election to be treated as a long-term UK resident
  • Section 267ZD Further provision about elections under section 267ZC
  • Section 267ZE Subject of domicile election treated as a long-term UK resident
  • Section 267ZF Double taxation conventions operating by reference to deemed domicile
  • Section 267A Limited liability partnerships.
  1. Miscellaneous
  2. Subject of domicile election treated as a long-term UK resident

Section 267ZE | Subject of domicile election treated as a long-term UK resident F1

From legislation.gov.uk

(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.

Notes

  1. F1

    Ss. 267ZC-267ZF inserted (6.4.2025) by Finance Act 2025 (c. 8), Sch. 13 paras. 27, 45(1)

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