Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Readers’ forum: Will executors be able to claim residence nil rate band on death?

14 April 2025
Issue: 4981 / Categories: Forum & Feedback , Inheritance Tax , Residence & domicile , Trusts

Non-resident settlor


Our clients are both non-UK domiciled and will remain non-UK domiciled under the new rules effective from April 2025.

Currently they own their main residence valued at £1 200 000 with no outstanding mortgage. They intend to sell this property and relocate to South Africa permanently.

Furthermore they plan to allocate £650 000 into a UK discretionary trust for the benefit of their children and grandchildren. The remaining £550 000 will be invested in shares within the UK.

In addition they own a property in South Africa valued at £400 000 which will serve as their main residence upon their return to South Africa.

They intend to gift this property to their children upon the second death. On the first death they will leave their respective shares of the estate to one another.

My question is as follows: will the executors in the...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon