There are new tax rules applying to inheritance tax in the UK. These were announced in the Autumn Budget Statement in October 2016.  As from April 2017, if you are tax resident in the UK for 15 of the previous 20 tax years, you will be deemed UK domiciled for all tax purposes, including inheritance tax. Inheritance tax in the UK is subject to your domicile. Domicile is determined by where you intend to permanently settle. If for example, you have an Italian father, you will acquire the domicile of your father under English common law principles.  However, if you choose to live permanently in the UK you may acquire an English domicile. This is known as a domicile of choice. Usually, it is difficult to lose a domicile of origin.

If you are domiciled in Italy, France, India or Pakistan, the provision of the Inheritance Tax 1984 preserves the application of the double tax treaties with those countries. Therefore, despite the new rules on deemed domicile, UK inheritance tax will not necessarily apply to your non-UK property, provided that you are non-domiciled and are covered by the double tax treaties of Italy, France, India and Pakistan.