Ceasing to be deemed domiciled: 7-year gift rule and inheritance tax

John was a UK tax resident continuously from 1987 but left the UK for good on 2 April 2023 and is (and will continue to be) a tax resident of Greece, the country of domicile by birth. Given the length of John's past stay in the UK, he was and continues to be "deemed domiciled" in the UK for inheritance and gift tax purposes. The HMRC however states that "You can lose deemed domiciled status under Condition B, if you leave the UK and there are at least 6 tax years as a non UK resident in the 20 tax years before the relevant tax year." Since John left the UK just before the end of the 22/23 tax year (i.e. 2/4/23), what is the EXACT date that John will cease to be deemed domiciled (assuming that he will never become a UK tax resident again)? Assuming that John makes a gift at some point BEFORE the day he loses deemed domiciled status, how does the 7 year rule work? For example, John makes a gift e.g. exactly 3 years before the end of his deemed domiciled status, does that mean that after 3 years (i.e. when he is not deemed domiciled any longer) the 7 year rule ceases to apply and even if he dies soon thereafter, the gift will not be taxed at all? Same question applies to inheritance tax on John's estate: will his estate be exempt from inheritance tax from the date he loses deemed domiciled status?

Hi,

HMRC cannot advise you on this as your residence is for you to determine based on the guidace available.

Thank you.