Singapore VCC insights

UK Non-Dom Moving to Singapore: The IHT Tail, Exit Timeline and Where the Family Office Sits

By VCC Editorial Team · Published 12 October 2026

Short answer: A UK non-dom moving to Singapore no longer escapes UK inheritance tax on departure. Since 6 April 2025 a long-term UK resident keeps worldwide inheritance tax exposure for 3 to 10 tax years after departure, depending on years of residence. Singapore has no estate duty and exempts most remitted foreign income for individuals, but it cannot shorten that UK tail.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

For a UK non-dom moving to Singapore, the label itself is now out of date. The United Kingdom replaced domicile with a residence-based system from 6 April 2025, and that change reshapes the exit plan for any family that has spent a decade or more in London. This article covers the departure year, the inheritance tax tail, trusts and family office location, and what Singapore does and does not solve. All UK and Singapore sources cited were checked on 12 October 2026.

What changed for UK non-doms on 6 April 2025?

The UK abolished the remittance basis and replaced domicile with tests based on years of UK tax residence. HMRC’s helpsheet HS266 states that from 6 April 2025 “all UK residents are taxed on the arising basis of assessment on their worldwide income and gains.”

Part 2 of the Finance Act 2025 (“Replacement of special rules relating to domicile”) contains the main pieces. Section 40 ends the remittance basis after 2024-25. Sections 37 to 39 create the four-year foreign income and gains (FIG) regime, which lets “qualifying new residents” claim relief on foreign income and gains arising in their first 4 years of UK residence after at least 10 consecutive tax years of non-residence. Section 41 introduces the TRF for pre-6 April 2025 foreign income and gains of former remittance basis users. Sections 44 and 45 replace the domicile test for excluded property, including settled property, with a long-term residence test.

In fairness to the UK, the new system is simpler to apply than common law domicile and the FIG regime is generous to newcomers. The cost falls on long-staying former non-doms, whose residence years do not switch off when they leave.

How does the inheritance tax tail work after you leave the UK?

If you are a long-term UK resident when you leave, your non-UK assets stay within UK IHT for between 3 and 10 tax years. HMRC guidance states: “You can still keep long-term UK residence for up to 10 tax years after you leave the UK.”

The HMRC Inheritance Tax Manual at IHTM47020 sets out the full scale, which depends on UK residence years within the previous 20:

UK residence years (of previous 20)	Tax years in scope for IHT after leaving
13 or fewer (but at least 10)	3
14	4
15	5
16	6
17	7
18	8
19	9
20	10

Three practical points. First, a split year under the statutory residence test counts as a full year of UK residence for IHT, so the departure year adds to the count. Second, the tail requires consecutive years of non-residence; a return visit that makes you UK resident for a year restarts the clock. Third, HMRC’s guidance states that “Inheritance Tax is charged on transfers of overseas assets you owned outright, or on death, when you are long-term UK resident.” The standard rate on death is 40% above the nil-rate band of £325,000. UK assets, including indirectly held UK residential property, remain within IHT whatever your residence status.

Narrower transitional rules apply to some people who were non-UK resident in 2025-26; check them against HMRC’s long-term residence guidance.

How do you exit UK tax residence under the statutory residence test?

UK residence is decided tax year by tax year under the statutory residence test in Schedule 45 to the Finance Act 2013. The cleanest exit for a departing principal is usually one of the automatic overseas tests, set out in HMRC’s RDR3 guidance note:

1. First automatic overseas test: you were UK resident in one or more of the previous 3 tax years and spend fewer than 16 days in the UK in the tax year.
2. Third automatic overseas test: you work full-time overseas, spend fewer than 91 days in the UK, work more than 3 hours on fewer than 31 UK days, and take no significant break from overseas work.
3. If neither applies, check the automatic UK tests (183 days or more in the UK; a UK home where you spend at least 30 days, with no overseas home or one you use for fewer than 30 days; full-time UK work).
4. If none of the automatic tests decides the year, apply the sufficient ties test. A leaver who was UK resident in any of the previous 3 years is resident with 16 to 45 UK days if they have at least 4 ties, and with more than 120 days if they have just 1.
5. For the departure year itself, check whether split year cases 1 to 3 apply, so that the overseas part of the year is treated separately for income tax and capital gains tax.

A London house, children in UK schools or a UK board seat each create ties, so families keeping any of them should model the ties test carefully.

What do the temporary non-residence rules catch?

If you return to the UK within 5 years, certain gains and income realised while abroad can be taxed in the year you come back. RDR3 states the rules apply if you had sole UK residence in 4 or more of the 7 tax years before departure and “your period of non-residence lasts 5 years or less.”

HMRC’s helpsheet HS278 lists the scope, including gains on assets held before departure, close company distributions, certain pension lump sums and offshore income gains. A UK non-dom moving to Singapore who sells a pre-departure portfolio in year 2 and then returns in year 4 can find the gain taxed in the UK in the year of return. Assets both bought and sold during the absence are generally outside these rules. For a principal with 15 years of UK residence, the 5-year temporary non-residence window and the 5-year IHT tail end at roughly the same time, which simplifies planning.

UK non-dom moving to Singapore: what does the year 0 to year 10 timeline look like?

The table below follows an illustrative principal who has been UK resident for 15 of the last 20 tax years, leaves for Singapore during 2026-27 and does not return. It assumes the overseas tests are met from 2027-28 and that any family trust was settled by the principal after 30 October 2024.

Period	UK income tax and CGT	UK IHT on non-UK assets	Settlor trust	Singapore position
Year 0: 2026-27 (departure)	UK resident; split year may apply; TRF designation still available at 12% if a former remittance basis user	In scope; year counts as UK residence	Additions of foreign assets are chargeable transfers while the settlor is long-term resident	Arrival; tax residence assessed by calendar year
Years 1 to 5: 2027-28 to 2031-32	Non-resident; CGT generally limited to UK land and UK branch assets; temporary non-residence exposure if the principal returns	Still long-term UK resident; worldwide assets in scope	Any 10-year anniversary charge in this window applies at up to 6%	Resident if 183-day or other IRAS tests met; remitted foreign income generally exempt
Year 6: from 6 April 2032	Non-resident; temporary non-residence window has closed	No longer long-term resident; only UK assets in scope	Proportionate exit charge when the settlor ceases to be long-term resident; foreign property then excluded property	No estate duty
After 10 consecutive non-resident years: from 2037-38	On a return to the UK, the 4-year FIG regime becomes available	Long-term residence test effectively reset if the principal returns	New settlements of foreign assets carry no entry charge while the settlor is not long-term resident	No estate duty

The dates follow HMRC’s own worked example in IHTM47020, where a person whose last UK resident year is 2026-27 and who has 18 years of residence stays long-term resident “until 6 April 2035”.

Where should the family office and trust sit during the tail?

During the tail, put operating decisions in Singapore and be careful about funding trusts. The tail is the period when UK charges are still live and Singapore cannot switch them off.

On trusts, HMRC’s manual at IHTM47052 sets out the rules for foreign property held in a trust the principal set up. While the settlor is long-term UK resident, foreign trust property is relevant property: a 10-year anniversary falling in that period carries a charge of up to 6%, and “there will also be a proportionate charge … when a settlor ceases to be long-term UK resident.” Once the settlor is no longer long-term resident, adding foreign property to a settlement is not a chargeable transfer. Deferring new settlements until the tail ends is often the cheaper sequence. If the settlor can benefit from the trust, the gift-with-reservation rules may bring the property into the death estate while the settlor is long-term resident. Trusts funded before 30 October 2024 while the settlor was non-UK domiciled may have transitional protection on death, which should be confirmed asset by asset. For the trustee side in Singapore, see our note on private trust companies in Singapore.

On the family office, IRAS treats a company’s tax residence as a question of where control and management is exercised, usually where the board takes strategic decisions. A principal who still chairs board meetings from London in the departure year sends mixed signals. Hold board meetings in Singapore, keep Singapore-based decision-makers and document it.

On regulation, the Monetary Authority of Singapore’s (MAS) revised framework for single family offices took effect on 15 June 2026. A qualifying single family office relies on a class exemption, notifies MAS within 14 days of starting business in Singapore, keeps an account with a MAS-licensed bank and files an annual return. Existing offices have until 15 June 2027 to comply; our transition guide covers the options, and the minimum AUM guide covers the 13O and 13U incentive thresholds.

What does Singapore offer, and what does it not solve?

Singapore offers no estate duty, no tax on capital gains that are capital rather than trading in nature, and an exemption for most foreign income that individuals remit. It does not remove UK IHT during the tail, UK temporary non-residence charges, or UK tax on UK assets.

IRAS’s e-Tax Guide “Tax Exemption for Foreign-Sourced Income (Fifth Edition)” (30 January 2026) states that from 1 January 2004 “all foreign-sourced income received in Singapore by resident individuals, except those received through a Singapore partnership, will be exempt from tax”. Income from a trade or business carried on in Singapore is outside that exemption. Resident individuals pay progressive rates up to 24% on chargeable income above S$1,000,000 from YA 2024. IRAS confirms that estate duty does not apply to deaths on or after 15 February 2008; see our article on whether Singapore has estate tax. For entities, s 10L of the Income Tax Act 1947 taxes foreign disposal gains received in Singapore by entities of a relevant group that lack adequate economic substance, for disposals on or after 1 January 2024.

The UK-Singapore double taxation agreement of 1997, as amended by the 2010 and 2012 protocols and modified by the Multilateral Instrument, covers UK income tax, corporation tax and capital gains tax and Singapore income tax (Article 2). It does not cover inheritance tax, so there is no treaty relief against the IHT tail.

Immigration is the other practical gate: the right to live in Singapore depends on holding a pass. Our sister practice, Singapore Employment Agency, handles pass applications for principals and family office staff. Our legal checklist for moving assets to Singapore covers the banking and custody side.

Frequently asked questions

Does the UK-Singapore tax treaty protect me from UK inheritance tax?

No. Article 2 of the 1997 agreement limits it to taxes on income and capital gains: UK income tax, corporation tax and capital gains tax, and Singapore income tax. Inheritance tax falls outside it, and Singapore has no estate duty to credit against it.

Can I still use the Temporary Repatriation Facility after I move?

Only for a tax year in which you are UK resident. HMRC’s manual at RDRM73200 confirms that an individual who is non-UK resident under the statutory residence test for a tax year cannot make a designation election for that year. A departure-year designation at 12% for 2026-27 may therefore be the last opportunity.

Will Singapore tax money I bring in from my overseas portfolio?

Generally not for an individual, provided it is foreign-sourced, not received through a Singapore partnership and not income from a trade or business carried on in Singapore. Entities are subject to separate rules, including s 10L for certain foreign disposal gains.

What happens if I come back to London after three years?

The temporary non-residence rules may tax gains on assets you held before leaving, and certain income, in the year you return. For IHT, you would also stop the run of consecutive non-resident years, so long-term residence status may continue.

Can I keep a home in London?

You can, but a UK home is an accommodation tie and can trigger the second automatic UK test if you have no overseas home or spend fewer than 30 days in it. Each tax year must be tested separately under the statutory residence test.

Sources

• HMRC: Inheritance Tax if you’re a long-term UK resident
• HMRC Inheritance Tax Manual IHTM47020: Long-term UK residence test
• HMRC RDR3: Statutory Residence Test notes
• Finance Act 2025 (legislation.gov.uk)
• IRAS e-Tax Guide: Tax Exemption for Foreign-Sourced Income (Fifth Edition)

Raffles Corporate Services helps families leaving the UK set up and run a Singapore family office, from VCC incorporation and family office structuring to ongoing compliance. Where UK tax advice is needed, a UK-qualified adviser should be instructed alongside us so that the Singapore structure fits the UK exit timeline. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 12 October 2026. The Editorial Team, Variable Capital Companies Act.