Your day counts have a longer relevance to your tax residency status than you might initially think. It’s not purely a matter of staying under the threshold this year and then forgetting about it. There are longer calculations at play for the UK long-term residence (LTR), and these have become significantly more consequential since the abolition of the non-dom framework in April 2025.
How you spend your time in the UK doesn’t just affect this tax year’s residency position. It feeds into a cumulative count that, once it reaches a certain point, can fundamentally change the scope of your tax exposure for years, and potentially decades, to come.
Let’s take a look at what the UK LTR status is, how it is determined, and why the number of days you have spent in the UK across many years is central to understanding your position.
This article is for general information only. It does not constitute tax or legal advice. If you have questions about your personal tax residency position, please speak with a qualified tax advisor.
From 6 April 2025, the UK introduced a new residence-based framework for inheritance tax (IHT). Under this framework, an individual is classified as a Long-Term UK Resident (LTR) if they have been a UK tax resident for at least 10 of the previous 20 tax years.
This replaced the previous domicile-based system, under which non-UK domiciled individuals became ‘deemed domiciled’, and therefore subject to IHT on worldwide assets after 15 years of UK residence.
The practical consequence is significant. Before LTR status applies, UK Inheritance Tax (IHT) generally applies only to UK-situated assets. Once an individual becomes a Long-Term Resident, their worldwide assets fall within the scope of UK IHT regardless of where those assets are held, and regardless of where the individual was born or considers home.
The 10-year threshold is calculated across a 20-year lookback window, and the years do not need to be consecutive. This is the element most likely to surprise internationally mobile individuals who have divided their time across multiple countries.
Someone who spent several years in the UK earlier in their life, left, and has since returned may find that those earlier years still matter. A period of residence from 2015 to 2019, followed by a return from 2025 onwards, would already have four years as a tax resident within the 20-year window by 2035.
There is a further nuance that catches many people off guard: split years count as full years. Under UK tax rules, when an individual arrives in or departs from the UK partway through a tax year, they may be entitled to ‘split year treatment‘. Under this framework, a part of the year is treated as UK residence, and part is not. For income tax purposes, this can be beneficial because you only pay tax on income you spent as a UK resident. However, for the UK long-term residence 10-year test, a split year counts as a complete year of UK residence.
The result is that LTR status can be reached faster than an individual’s intuitive sense of their history might suggest.
Understanding what LTR status means in practice requires a qualified tax advisor to assess your specific position. What we can set out clearly is the general scope of the change.
For individuals who are not LTRs, UK IHT applies mostly to UK-situated assets. For those who are LTRs, the scope extends to worldwide assets, including overseas property, foreign investments, and assets held in offshore structures.
The treatment of offshore trusts also changes under the new rules. Where a trust has a living settlor, the trust’s exposure to IHT depends on whether the settlor holds LTR status. This represents a significant shift from the previous framework, under which certain offshore trust structures offered longer-term shelter from UK IHT.
Spousal and civil partner exemptions are also affected. Where one spouse is an LTR, and the other is not, the normally unlimited spousal exemption for IHT purposes could be restricted.
These are generalisations. The specifics depend on individual circumstances, asset structures, and the nature of any relevant double taxation treaties. The consistent message from tax professionals is that early and accurate assessment of LTR status is essential.
A point that surprises many people who have already relocated: LTR status does not switch off on the day you leave.
Once an individual has become an LTR, their worldwide estate remains within the scope of UK IHT for a period after departure — commonly referred to as the IHT tail. The length of this tail scales with how long the individual was UK resident:
| Number of UK residence years | Years in scope for IHT |
| 13 or less | 3 |
| 14 | 4 |
| 15 | 5 |
| 16 | 6 |
| 17 | 7 |
| 18 | 8 |
| 19 | 9 |
| 20 | 10 |
| Source: HMRC | |
Full UK long-term residence status only resets after 10 consecutive years of non-UK residence.
To use a straightforward illustration: an individual who was a UK resident for 15 years and relocated to another country in 2026 would, under the current general framework, remain within the UK IHT net on their worldwide assets until approximately 2031. This is a general illustration only, and individual circumstances will vary.
If you’ve recently moved away from the UK, or are considering doing so, understanding where you sit in this framework is a priority conversation to have with a professional tax advisor.
LTR status is determined by whether an individual was a UK tax resident in each of the relevant years. And UK tax residency, year by year, is determined by the Statutory Residence Test (SRT). This is a framework built on the number of days spent in the UK and the nature of an individual’s connections to it.
Along with the sufficient ties test, the number of days you spend in the UK each year determines whether that year counts as a year of UK residence. This is why day counting isn’t only a year-to-year compliance discipline. Each year feeds directly into the cumulative LTR assessment.
And the day counting thresholds that you need to keep in mind can vary, depending on your previous years’ tax residency status and your ties to the UK.
This type of day counting complexity for UK tax residency means your records matter more than ever. Establishing your LTR status requires demonstrating how many days you spent in the UK over many years. Relying on memory, bank statements, or fragmented travel records for events a decade ago creates genuine evidential risk. Contemporaneous records, logged at the time, are the foundation of a defensible position.
From April 2025, an individual is classified as a Long-Term UK Resident (LTR) for inheritance tax purposes if they have been a UK tax resident for at least 10 of the previous 20 tax years. LTR status determines whether an individual’s worldwide assets, not just UK-situated ones, fall within the scope of UK IHT.
The threshold is 10 years of UK tax residence within a 20-year lookback window. The years do not need to be consecutive. This replaced the previous 15-year deemed domicile threshold from 6 April 2025.
Yes. Under the current rules, a tax year in which an individual has split year treatment still counts as a full year of UK residence for the purposes of the LTR 10-year test.
LTR status does not end immediately on departure. A tail applies, ranging from 3 years (for those resident for 10–13 years) up to a maximum of 10 years (for those resident for 20 years or more). Full LTR status resets only after 10 consecutive years of non-UK residence.
Daysium’s Day Count Confidence Check gives you a clear view of where you currently stand with your record-keeping. The quick assessment helps you identify potential risks, and we’ll provide you with actionable steps to improve your record-keeping whether counting towards UK long-term residence or other reasons.
Take the Day Count Confidence Check.
Whether you are actively planning a move to or out of the UK, creating strong day counting records helps support your future position. Start your record-keeping journey today to have the confidence to state tomorrow, “There’s nothing to see here; everything is in order.”
Created in partnership with industry experts, tackle the complex challenges of day counting and tax record-keeping.
Most day counting apps record where your device was. That is not the same as building a contemporaneous evidence record that holds up in an HMRC residency enquiry. This guide covers spreadsheets, day counting apps, and what the best tax residency app for HNWIs actually needs to do — including what an enquiry costs if your records do not hold up.
Globally mobile creatives live across borders — but tax residency rules still count days. In this conversation with Richard Paul, we explore why strong travel records matter more than ever.
What are exit taxes? In an increasingly mobile world, more countries are taxing unrealised gains when individuals move abroad. This article explains how exit taxes work, why they matter for HNWIs, where they’re used today, and the key factors to consider when planning a relocation, especially the importance of tax residency and robust evidence.
UK non-dom reforms are raising the bar for trust compliance. Trustees can no longer rely on intent; they must be able to produce consistent, audit-ready tax residency evidence. Cowritten with Trident Tax, this article explores why traditional records fall short, how technology is reshaping standards, and what both Channel Islands and UK onshore trustees should do now.