IHTM47024 - Long-term UK residence: Young persons
For a young person听under the age of 20, the long-term听鲍碍听residence test is modified by听滨贬罢础84/厂6叠,听so that a听young person听will be a long-term UK resident听(IHTM47000)听if they have been resident in the UK for Income Tax purposes for at least 50% of the tax years since their birth听(rounded up to the next whole number).听For the purposes of this calculation听it is necessary听to count the number of whole tax years for which the young person has been alive before the current tax year.听
Where a young person under the age of 20 satisfies the modified long-term UK residence test and then leaves the UK,听they will remain in scope for a period of time determined by the length of their UK residence under S6A(3), subject to a minimum 3 year period听in the same way as an adult (IHTM047020).听
A young person听is not a long-term UK resident at any time in a tax year if they were under the age of 1 (or were not yet born) immediately听before the tax year.听
Example 1听
Michaela听was born on 1 April 2006 and听leaves the UK at the age of 19听on 1 September 2025听having been UK resident since her birth. The modified long-term UK residence test means that Michaela will be听a long-term UK resident if she has been resident in the UK for at least 10听of the 19 whole tax years听since her birth.听
19 x 50% = 9.5听
Rounded to the next whole number = 10听
Michaela satisfies the modified long-term听鲍碍听residence test听as she has been resident in the UK for at least 10听out of the 19听whole tax years听since听her birth听as per S6B(1)听IHTA84听
Michaela will听remain in scope for IHT purposes for 9听years听as听the number of her resident听years听in the UK is 19 as per S6A(3)听IHTA84听
Example 2听
Manuel was born on 6 April 2026 and leaves the UK听on听15 October 2030 at the age of 4听having been UK resident since his birth. The modified long-term听鲍碍 residence test听means that Manuel will be听a long-term UK resident if he has been resident in the UK for at least 2 out听of the 4 whole tax years听since his birth.听
4 x 50% = 2听
Manuel satisfies the modified听long-term UK residence test听as he has been resident in the UK for at least 2听of the 4听whole tax years since听his birth as per S6B(1)听IHTA 84.听
Manuel will remain in scope for IHT purposes for the minimum听period of 3 years听as the number of his resident years in the UK is 4 as per S6A(3) IHTA84.听
Example 3听
Jasper听was born in Argentina on 6 April 2023.听听
He听came to the UK on 6 April 2025 to 10 April 2027.听He then went to Hong Kong for 5听years听and arrived back in the UK on听7 April 2032.听
He stayed in the UK for 3 years听before a听period听of education听in the US on 15 May听2035.听
On 31 March听2037, he returns to the UK for 1听year听before leaving the UK permanently听on 1 June 2038 when he听is 15 years old.听
The modified long-term UK residence test means that Jasper will be a long-term UK resident if he has been resident in the UK for at least 8听of the 15 whole听tax years since his birth.听
15 x50% = 7.5听
Rounded to the next whole number = 8听
Jasper does not satisfy the modified long-term UK residence test as he was not resident in the UK听for at least 8听of the 15 whole tax years听since听his birth as per S6B(1) IHTA84. He was only resident in the UK for a total of 6 whole tax years.听听
Jasper does not therefore satisfy the modified long-term UK residence test.听