Section 73 | Relevant property: disapplication of exemptions from exit charges

(1)In IHTA 1984, in section 65 (relevant property: exit charges), after subsection (8A) insert—

(8B)None of subsections (7), (7A) and (8) applies in relation to property comprised in a settlement if—

(a)a long-term residence change took place at a time—

(i)before the event in question, and

(ii)if there have been one or more ten-year anniversaries before the event in question, after the most recent of them,

(b)the long-term residence change did not result in tax being charged under this section by reference to the property, and

(c)the long-term residence change would have resulted in tax being charged under this section by reference to the property if the property had been property situated outside the United Kingdom when the long-term residence change took place.

(8C)In subsection (8B) “long-term residence change” means—

(a)the settlor not being a long-term UK resident at the start of the tax year 2025-26, or

(b)the settlor ceasing to be a long-term UK resident at the start of any later tax year.

(2)The amendment made by subsection (1) is treated as having come into force on 26 November 2025.