| ★ TL;DR TL;DR: The UK expat guide 2026 covers the complete financial and legal landscape for UK nationals living abroad or planning to relocate: Statutory Residence Test, Finance Act 2025 FIG regime and non-dom abolition, UK State Pension (35 qualifying years, £221.20/week), property income rates 22%/42%/47% from 6 April 2026, pensions in IHT from 6 April 2027, residence-based IHT (10-year rule), banking, investments, healthcare, and estate planning. All major 2025-2026 Budget changes summarised in one place. |
| ⚠ UPDATED 26 APR 2026 What changed in the 2025-2026 Budgets This guide reflects UK rules as published. The following changes from the Spring 2024, Autumn 2024 and Autumn 2025 Budgets affect the figures referenced below. Always refer to the current rate schedule on gov.uk before acting:
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Last reviewed: 26 April 2026
The UK expat guide 2026 is the master reference for UK nationals living abroad or planning to relocate -- covering tax residency, pensions, property, banking, investments, healthcare, estate planning, and the major legislative changes of 2025-2026 that have fundamentally altered the UK’s international tax landscape. The UK expat population is estimated at approximately 5.5 million people worldwide; each faces a distinct combination of UK and foreign tax obligations, visa requirements, and financial planning challenges. This guide provides an executive overview of each major domain; follow the deep-dive links throughout for detailed guidance. For the foundational UK tax residency rules that underpin almost every decision in this guide, see our UK tax residency guide. For UK pension planning abroad, see our UK pension abroad guide. For investment account management from abroad, see our UK expat investments guide.
The UK expat guide 2026 is published at a time of major transition in UK international tax rules. The Finance Act 2025 abolished the 250-year-old non-domicile remittance basis from 6 April 2025; introduced the 4-year FIG (Foreign Income and Gains) regime for new UK arrivals; replaced domicile-based IHT with 10-year residence-based IHT; and the Autumn Budget 2025 changed UK property income tax rates, dividend rates, and extended the NI threshold freeze to April 2031. For UK expats, these changes affect tax on foreign income, inheritance tax exposure, and the structure of pension and investment planning. The Autumn Budget 2025 OOTLAR (gov.uk/government/publications/autumn-budget-2025-overview-of-tax-legislation-and-rates-ootlar) and HMRC’s RDR1 (gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis) are the authoritative references for these changes; HMRC’s guidance publication on non-dom changes (gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals) is essential reading for former non-doms.
1. UK tax residency: the Statutory Residence Test
Whether you are a UK tax resident is determined by the Statutory Residence Test (SRT, Finance Act 2013, gov.uk/guidance/the-statutory-residence-test-srt) -- a bright-line test applied annually to each individual’s circumstances. The SRT has three components: automatic UK non-residence (if fewer than 16 days in the UK in a tax year with no UK ties; or fewer than 46 days with no ties from prior years); automatic UK residence (if 183+ days in the UK in any tax year, or if the UK is the only home for 91+ days); and sufficient ties tests for those in between (UK ties include family, accommodation, work, and 90-day ties that affect how many days in the UK trigger residence). UK tax residents are taxed on worldwide income; non-UK-residents are taxed only on UK-source income. The SRT split-year treatment allows the tax year to be divided if an individual arrives or departs the UK partway through the year. See our detailed UK tax residency guide for the full SRT framework, split-year cases, and examples. Every subsequent section of this UK expat guide 2026 depends on the SRT result.
2. What changed in the 2025-2026 Budgets
The 2024-2026 Budget cycle produced more UK international tax change than any period since the introduction of the SRT in 2013. Key changes UK expats must understand: (1) Non-dom abolition and 4-year FIG regime (Finance Act 2025, from 6 April 2025): the remittance basis was abolished; qualifying new UK arrivals (not UK-resident in any of the prior 10 consecutive tax years) receive 4 years of full foreign income and gains exemption without a remittance test. See our non-dom abolition 2025 impact guide. (2) Temporary Repatriation Facility (TRF): pre-2025 unremitted foreign income can be brought to the UK at 12% (2025/26 + 2026/27) or 15% (2027/28). (3) Residence-based IHT (from 6 April 2025): 10 of the prior 20 tax years UK-resident = worldwide IHT estate with 10-year tail after departure. (4) Pensions in IHT (from 6 April 2027): undrawn pension funds enter the UK IHT estate. (5) Dividend rates from 6 April 2026: 10.75%/35.75%/39.35% (from 8.75%/33.75%). (6) Property income rates from 6 April 2026: 22%/42%/47% separate rates replacing 20%/40%/45%. (7) NI thresholds frozen to April 2031 (Autumn Budget 2025 OOTLAR). (8) Non-resident dividend credit abolished 6 April 2026. All rates confirmed at Autumn Budget 2025 OOTLAR (gov.uk/government/publications/autumn-budget-2025-overview-of-tax-legislation-and-rates-ootlar).
3. UK income tax on foreign income and double taxation
Non-UK-resident individuals pay UK income tax only on UK-source income: UK rental income, UK employment income for UK duties, UK pension income (where no NT code is in place), and UK dividends above the £500 allowance. Foreign income (overseas salary, overseas rental, overseas dividends) is not UK-taxable for non-UK-residents. UK residents are taxed on worldwide income unless they qualify for the 4-year FIG regime. The FIG regime (Finance Act 2025) provides full exemption on foreign income and gains for 4 years for qualifying new arrivals. For pre-2025 unremitted foreign income, the TRF (12%-15% flat rate) applies. UK double tax conventions (DTCs, 130+ in the UK network, gov.uk/government/collections/tax-treaties) prevent double taxation on cross-border income -- allocating taxing rights between the UK and the country of residence. See our UK double taxation agreements guide and our guide on UK tax on foreign income for the detailed frameworks. UK Self Assessment (SA100 + SA109 for non-residents, SA106 for foreign income) governs the annual reporting framework; the online filing deadline is 31 January following the tax year.
4. UK State Pension for expats
The full new UK State Pension is £221.20 per week for 2025/26, requiring 35 qualifying years of National Insurance contributions or credits (gov.uk/new-state-pension/eligibility). A minimum of 10 qualifying years is needed for any State Pension entitlement at all. Voluntary NIC top-ups: Class 2 (for self-employed abroad) costs £3.45/week; Class 3 (for employed/non-working abroad) costs £17.45/week for 2025/26. A special transitional window (open until 5 April 2027) allows UK nationals to fill NI gaps back to the 2006/07 tax year -- a once-in-a-generation opportunity to boost State Pension entitlement significantly. Frozen vs uprated: UK State Pension is uprated annually (triple-lock) for residents of countries with a UK reciprocal social security agreement (EU, USA, Barbados, Bermuda, etc.); it is frozen at the rate when first claimed for residents of Australia, New Zealand, Canada, and many other countries. See our UK State Pension abroad guide for the full frozen vs uprated country list. State Pension age is currently 66 for all.
5. UK private pensions and SIPP abroad
UK nationals abroad can continue contributing to a UK SIPP (Self-Invested Personal Pension) subject to the Annual Allowance (£60,000 for 2025/26) and the 100% of relevant UK earnings cap (with a minimum of £3,600 gross per year for non-earners). The Money Purchase Annual Allowance (MPAA) of £10,000 applies if drawdown income has been taken; the Tapered Annual Allowance reduces the £60,000 for those with adjusted income above £260,000. SIPP drawdown income paid to non-UK-residents is generally taxable only in the country of residence under the relevant DTC pension article (OECD Model Article 17). UK government service pensions (NHS, civil service, armed forces, teachers) remain UK-taxable regardless of residency under Article 19. From 6 April 2027, undrawn pension funds enter the UK IHT estate -- changing drawdown timing decisions fundamentally. QROPS (Qualifying Recognised Overseas Pension Scheme) transfers are available but heavily regulated -- most Australian super funds are not on the HMRC ROPS list, creating an unauthorised payment risk. See our UK pensions for expats guide and our QROPS explained guide.
6. UK property: letting from abroad and buying overseas
UK nationals who own UK property and move abroad must register with the Non-Resident Landlord Scheme (NRLS, gov.uk/tax-uk-income-live-abroad/rent): letting agents or tenants withhold 20% basic-rate tax from gross rent. UK property income tax rates from 6 April 2026: 22% basic / 42% higher / 47% additional (Autumn Budget 2025 OOTLAR) -- higher than the old 20%/40%/45% alignment with income tax. Section 24 restricts mortgage interest to a 20% basic-rate tax credit only. Non-resident UK landlords file SA100 + SA105 + SA109 annually (online deadline 31 January). NRCGT (Non-Resident Capital Gains Tax) applies at 18%/24% on disposal of UK residential property; a 60-day NRCGT return must be filed within 60 days of completion. UK property is always within the UK IHT estate regardless of the owner’s residency. Buying overseas property: Finance Act 2025 residence-based IHT means long-term UK residents’ overseas property is within the worldwide UK IHT estate during the tail period. See our UK expat property guide, buy-to-let from abroad guide, and UK landlord tax guide.
7. Banking and currency management
UK expats face two banking challenges: maintaining a UK bank account from abroad (many UK high-street banks close accounts for non-UK-residents citing KYC compliance), and managing regular GBP-to-local-currency transfers efficiently. On UK bank account access: digital banks (Starling, Monzo) and some building societies are more flexible than high-street banks for non-resident account maintenance. Offshore banking (Isle of Man, Jersey, Guernsey) provides a UK-jurisdiction account with non-resident access; FSCS protection (£85,000 per depositor) does not apply to offshore accounts, but Channel Islands’ Depositor Compensation Schemes provide comparable coverage. For currency transfers: both FCA-authorised specialist currency providers and digital transfer services operate in this space; the FCA Register at register.fca.org.uk verifies any provider’s regulatory status. See our UK expat banking guide, offshore bank account guide, and how to open a UK bank account as a non-resident guide.
8. UK ISAs and investment accounts abroad
ISAs (Individual Savings Accounts) cannot be opened or contributed to by non-UK-residents (HMRC rules, gov.uk/individual-savings-accounts); existing ISAs can be maintained while abroad but no new contributions are permitted. ISA tax relief (income tax and CGT-free) applies only during UK residency; whether the country of residence also taxes ISA income/gains is determined by the applicable DTC. General Investment Accounts (GIAs) held by non-UK-residents are subject to UK CGT only on UK-sited assets; foreign assets in a GIA are not UK-CGT-taxable for non-residents (though possibly taxable in the country of residence). From 6 April 2026, UK dividend rates are 10.75%/35.75%/39.35% -- for UK-resident investors; non-residents pay DTC withholding rates (0-15%). EIS (Enterprise Investment Scheme) and VCT (Venture Capital Trust) investments: generally not accessible to non-UK-resident investors for income tax relief purposes. See our UK expat ISA guide, EIS guide for UK expats, and VCT guide for UK expats.
9. International health insurance
UK expats typically lose NHS entitlement on becoming non-UK-resident (though Emergency treatment in the UK remains available, and some S1 rights apply for pensioners in EU countries); comprehensive international private medical insurance (IPMI) is essential. Key features to assess: worldwide vs excluding USA coverage; inpatient only vs comprehensive (inpatient + outpatient + dental + mental health); annual limit (minimum USD 1-2m for serious illness); pre-existing condition handling (moratorium vs full underwriting); direct billing vs reimbursement; and deductible/excess levels. UK-headquartered FCA-authorised IPMI providers include Bupa Global, Cigna Global Health Options, Aetna International, and AXA Global Healthcare. UK Insurance Premium Tax (IPT) at 12% applies to UK-regulated policies; some international policies issued outside the UK are not subject to IPT. See our UK expat health insurance guide and our best international health insurance guide for provider comparisons.
10. Inheritance tax and estate planning
UK IHT from 6 April 2025 operates on a residence-based framework (Finance Act 2025): individuals UK-resident in at least 10 of the prior 20 tax years are long-term UK residents (LTRs) subject to UK IHT at 40% above the nil-rate band (£325,000 for 2025/26, frozen to April 2030) on their worldwide estate -- including overseas property, overseas bank accounts, and overseas investments. The LTR tail period extends up to 10 years after departure. From 6 April 2027, undrawn pension funds also enter the UK IHT estate. Non-UK-domicile is no longer the relevant test; domicile has been replaced by the LTR residence-based test. Key planning tools: the 7-year PET (Potentially Exempt Transfer) rule allows outright gifts to fall outside the IHT estate if the donor survives 7 years; the Business Relief and Agricultural Relief exemptions remain; life insurance in trust can be used to fund the IHT liability; offshore bonds may provide tax deferral options. See our UK expat estate planning guide, UK expat wills abroad guide, and UK inheritance tax for expats guide.
11. Non-dom abolition: the FIG regime and TRF in detail
The Finance Act 2025 (Schedule 9, from 6 April 2025) abolished the UK non-domicile remittance basis -- the mechanism that allowed non-UK-domiciled UK residents to shelter unremitted foreign income from UK tax. The replacement 4-year FIG (Foreign Income and Gains) regime: qualifying new UK arrivals (not UK-resident in any of the 10 prior consecutive tax years) are fully exempt from UK income tax and CGT on all foreign income and gains for their first 4 tax years of UK residency, without any remittance test. From year 5, worldwide income is fully UK-taxable. The Temporary Repatriation Facility (TRF): former non-doms with pre-2025 unremitted foreign income can designate amounts to be remitted to the UK at 12% (for 2025/26 and 2026/27) or 15% (2027/28). The TRF window closes 5 April 2028. The OBR estimated £2.7bn in additional annual revenue from the non-dom abolition. Affected categories: existing UK-resident non-doms (face full worldwide taxation from 6 April 2025 unless qualifying for FIG); returning UK expats with 10+ prior non-UK-residence years (qualify for FIG); former UK non-doms who have left the UK (pre-2025 offshore income addressable via TRF). See our non-dom abolition 2025 impact guide and our UK expat remittance basis guide.
12. Common destinations: tax and visa overview
UK expats concentrate in a small number of destinations; the key tax and visa features for the most popular are: UAE (Dubai) -- zero personal income tax, zero CGT, zero IHT; Employment Visa or Golden Visa; UK State Pension frozen; see our moving to Dubai guide. Spain -- Beckham Law (24% flat rate, tightened 2025) for qualifying employed professionals; Non-Lucrative Visa or Digital Nomad Visa; S1 healthcare for UK pensioners; UK-Spain DTC 2013 governs pensions; UK State Pension uprated; see our moving to Spain guide. Portugal -- IFICI (replacing NHR, 20% flat rate for qualifying innovation sector professionals); D7 passive income visa; UK State Pension uprated; see our moving to Portugal guide. Australia -- 0-45% income tax + 2% Medicare Levy; UK State Pension frozen; Reciprocal Healthcare Agreement for visitors; super-treaty gap; see our moving to Australia guide. Singapore -- 0-22% income tax; Employment Pass required; school fees high; UK State Pension frozen; see our moving to Singapore guide. Canada -- combined federal+provincial income tax up to 53.5%; UK State Pension uprated; OHIP public healthcare after 3-month wait; see our moving to Canada guide.
13. Self-employment and corporate structure abroad
UK expats who are self-employed or run UK limited companies face distinct compliance obligations. Key considerations: (1) UK Self Assessment filing (SA100 + SA103) is required for UK-source self-employment profits above the personal allowance (£12,570 for 2025/26), regardless of non-UK-residency; (2) Voluntary Class 2 NIC (£3.45/week, 2025/26) is available to self-employed UK nationals abroad to maintain UK State Pension entitlement; (3) IR35 (off-payroll working rules, gov.uk/guidance/understanding-off-payroll-working-ir35) applies to UK-source income from services provided to UK clients through a personal service company, even for non-UK-residents; (4) UK Ltd company directors extracting profit via dividends pay the new rates from 6 April 2026: 10.75%/35.75%/39.35% (Autumn Budget 2025 OOTLAR) if UK-resident; non-resident directors pay DTC withholding rates; (5) The FIG regime may exempt qualifying new UK arrivals from UK tax on foreign self-employment income for 4 years. See our UK expat self-employed tax guide for the complete framework.
14. Digital nomads and location-independent working
Location-independent working has become a defining feature of UK expat life in 2024-2026: remote work for UK employers from overseas, contracting for UK clients from abroad, or building a globally-distributed business. Key compliance points: (1) UK tax position -- non-UK-residents who perform work entirely outside the UK for non-UK clients generally have no UK income tax liability on that work; work performed in the UK for UK clients creates UK-source income taxable in the UK; (2) SRT -- care needed to stay below the relevant day-count thresholds (particularly the automatic overseas test’s 16/46/183-day limits); (3) PE risk -- performing UK business activities from overseas may create a permanent establishment in the overseas country, subjecting UK business profits to local tax; (4) Digital nomad visa options are expanding: Spain DNV (200% SMI, approximately EUR 2,646/month, Ley de Startups 2023), Portugal D8 (EUR 3,480/month), Thailand LTR, Germany Freiberufler, and others; (5) The UK-specific IR35 risk applies when UK clients use off-payroll engagement. See our digital nomad visa guide for country-by-country coverage.
15. Common compliance mistakes and how to avoid them
The five most common compliance mistakes among UK expats are: (1) Failing to file UK Self Assessment for UK rental income: non-UK-resident landlords must file SA100 + SA105 + SA109 annually regardless of whether the NRLS has withheld 20%; late-filing penalties begin at £100 from 1 February. (2) Assuming non-residency eliminates UK tax: UK-source income (pension, rental, dividends) remains UK-taxable for non-residents; only the rate and mechanism differ. (3) Missing the NI top-up April 2027 deadline: the transitional window to fill NI gaps back to 2006/07 closes 5 April 2027; the standard 6-year window resumes after that date. (4) Transferring UK pension to non-ROPS overseas scheme: UK-to-Australian super, UK-to-US 401K, or UK-to-non-ROPS transfers trigger unauthorised payment charges of 25-55%; verify ROPS status before any transfer. (5) Ignoring the 60-day NRCGT return on UK property disposal: a £100 late-filing penalty applies even where no CGT is due; the 60-day clock runs from completion (gov.uk/capital-gains-tax-for-non-residents-uk-residential-property). See our returning to the UK from abroad guide for the full repatriation compliance checklist.
16. Professional advice: who to engage
The complexity of UK expat tax, pension, and estate planning means that professional advice is not merely helpful but typically essential. Key professional categories: (1) Cross-border tax adviser: CIOT-qualified (Chartered Institute of Taxation, tax.org.uk) or CTA-qualified adviser with specific experience in UK non-resident taxation and the applicable DTC; many specialist expat tax firms operate remotely. (2) FCA-authorised independent financial adviser: For pension, investment, and insurance planning; verify FCA authorisation at register.fca.org.uk; look for Chartered Financial Planner (PFS, thepfs.org) designation for complex expat scenarios. (3) UK solicitor (property and estate): For UK property transactions, will drafting, and estate planning; the Law Society (lawsociety.org.uk) maintains a registered member directory; overseas property requires local legal counsel in addition. (4) Immigration solicitor: For UK visa applications, Indefinite Leave to Remain (ILR), or British nationality applications on return; OISC-regulated or Solicitor Regulation Authority (SRA) regulated for UK immigration matters. The combination of pre-departure tax planning, annual Self Assessment compliance, and periodic strategic review by qualified advisers is the standard approach for financially active UK expats. HMRC’s agent authorisation framework (gov.uk/guidance/client-authorisation-an-overview) allows advisers to act on behalf of UK expats for HMRC matters.
| ✓ Editorial Sources Sources used in this guide This guide draws on primary-source material from HMRC’s RDR1 (gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis -- SRT, FIG regime, TRF and residence-based IHT), the Autumn Budget 2025 OOTLAR (gov.uk/government/publications/autumn-budget-2025-overview-of-tax-legislation-and-rates-ootlar -- dividend rates, property rates, NI freeze), Finance Act 2025 Schedule 9 (abolition of non-dom remittance basis from 6 April 2025), HMRC’s Pensions Tax Manual (gov.uk/hmrc-internal-manuals/pensions-tax-manual -- pension IHT from April 2027, AA, MPAA), and HMRC’s IHT guidance (gov.uk/inheritance-tax -- 10-year residence-based IHT from 6 April 2025) as of 26 April 2026. Finance Act 2025 non-dom abolition and residence-based IHT are effective from 6 April 2025; dividend rates changed from 6 April 2026; pension IHT from 6 April 2027; NI thresholds frozen to April 2031. Readers should confirm current rules with a CIOT-qualified cross-border tax adviser and an FCA-authorised IFA before making decisions. |
This article is for general information only and does not constitute tax, legal, financial or immigration advice. Rules and rates change; verify with the primary sources cited or consult a qualified adviser before acting.
FAQ
What is the Statutory Residence Test and why does it matter for UK expats?
The SRT (Finance Act 2013, gov.uk/guidance/the-statutory-residence-test-srt) determines whether an individual is UK tax-resident in a given tax year. UK tax residents are taxed on worldwide income; non-UK-residents are taxed only on UK-source income. The SRT uses day-count tests (automatic non-residence below 16 days; automatic residence above 183 days) and "sufficient ties" tests for those in between. Every major financial decision for a UK expat -- from pension drawdown timing to property income to investment account contributions -- depends on the SRT outcome.
How has the non-dom abolition affected UK expats in 2025?
Finance Act 2025 (Schedule 9, from 6 April 2025) abolished the remittance basis, replacing it with the 4-year FIG regime for new UK arrivals (not UK-resident in any of the prior 10 years) and the TRF (12%-15%) for pre-2025 offshore income. Long-term UK non-doms who were UK-resident on 5 April 2025 face full worldwide UK taxation from 6 April 2025 (unless qualifying for FIG). Former UK non-doms who left the UK before 6 April 2025 have no new obligation for post-departure income but may use the TRF for pre-2025 unremitted amounts. OBR estimates £2.7bn in additional annual revenue.
What are the UK State Pension qualifying year requirements?
35 qualifying years of NI contributions or credits are required for the full new State Pension of £221.20 per week (2025/26). Minimum 10 qualifying years for any entitlement. Voluntary Class 2 NIC costs £3.45/week (self-employed abroad); Class 3 costs £17.45/week (employees or non-working). A special transitional window (closes 5 April 2027) allows filling NI gaps back to 2006/07 -- after this date, only the standard 6 prior years can be topped up. Check your qualifying year count at gov.uk/check-state-pension.
What are the new UK property income tax rates from April 2026?
Separate property income tax rates apply from 6 April 2026 (Autumn Budget 2025 OOTLAR): 22% basic rate (up to £50,270 combined income); 42% higher rate (£50,271 to £125,140); 47% additional rate (above £125,140). These replace the previous 20%/40%/45% alignment with standard income tax bands. Section 24 restricts mortgage interest to a 20% basic-rate tax credit. Non-resident landlords must file SA100 + SA105 + SA109 annually; the NRLS withholds 20% from gross rents pending Self Assessment.
Will my UK pension be subject to IHT from 2027?
From 6 April 2027 (Autumn Budget 2024), undrawn defined contribution pension funds, SIPP balances, and pension death benefits will be included in the UK IHT estate for qualifying individuals. Before April 2027, pension death benefits are generally outside the IHT estate. UK expats within the Finance Act 2025 IHT tail period with large pension pots should model pension drawdown timing before April 2027 -- drawing down incurs income tax in the country of residence (potentially at lower DTC rates) rather than UK IHT at 40% post-2027. HMRC’s Pensions Tax Manual covers the post-April 2027 framework.
What are the UK dividend tax rates for 2026?
UK dividend tax rates from 6 April 2026 (Autumn Budget 2025 OOTLAR): ordinary rate 10.75% (was 8.75%); upper rate 35.75% (was 33.75%); additional rate 39.35% (unchanged). These apply to UK-resident taxpayers on dividends above the £500 dividend allowance for 2025/26. Non-resident shareholders pay UK dividend withholding tax at the applicable DTC rate (typically 0-15%). Non-resident dividend credits were abolished from 6 April 2026; non-resident UK shareholders in UK companies no longer benefit from any notional dividend credit.
Sources
- HMRC -- Statutory Residence Test (SRT): automatic tests and sufficient ties (verified 26 April 2026)
- GOV.UK -- Changes to the taxation of non-UK domiciled individuals (FIG regime, TRF 12%/15%, Finance Act 2025) (verified 26 April 2026)
- GOV.UK -- Autumn Budget 2025 OOTLAR (dividend rates, property rates, NI freeze to April 2031) (verified 26 April 2026)
- HMRC -- Pensions Tax Manual (AA, MPAA, pension IHT from April 2027, NT code procedures) (verified 26 April 2026)
- GOV.UK -- UK IHT: Finance Act 2025 residence-based IHT (10-year LTR rule and tail period) (verified 26 April 2026)
- GOV.UK -- UK double tax treaty network (130+ DTCs, full text for each country) (verified 26 April 2026)