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The short answer
Since 6 April 2025, UK inheritance tax reaches your assets worldwide, including land, shares and bank accounts in Nigeria, once you are a long-term UK resident: UK resident for at least 10 of the 20 tax years before the year of death or gift. Below that, only UK assets are taxed. If you leave, you stay in scope for between 3 and 10 tax years, depending on how long you lived here.
Under the old rules, many Nigerians in Britain assumed their house in Lekki or their late father's land in Owerri was outside UK inheritance tax because they had a 'domicile of origin' in Nigeria. That reasoning no longer works for deaths and gifts from 6 April 2025. The test is now about how many years you have been UK tax resident, and the count catches most people who came on a work or study visa in the early 2010s and stayed.
The 10-of-20 test in plain terms
HMRC's manual (IHTM47020, updated 7 April 2026) says foreign assets you own outright are in scope for inheritance tax if you are a long-term UK resident, meaning UK resident for at least 10 out of the last 20 tax years. The 20 years counted are those immediately before the tax year of the event, such as a death or a gift. The test applies whatever your domicile.
- Residence for each year is decided as it is for income tax and capital gains tax, using the Statutory Residence Test from 2013-14 and the older rules before then.
- A split year counts as a full year of UK residence for this purpose.
- A UK tax year runs from 6 April to 5 April.
GOV.UK's page on deaths of people living abroad puts the other side: someone who lived in the UK for less than 10 of the last 20 years is 'based abroad' and pays inheritance tax only on UK assets. For deaths on or before 5 April 2025, the older domicile-based rules apply. To check how your own years count, see the Statutory Residence Test for Nigerians.
Counting your years: an example
Example: Tunde arrived as a student in September 2014 and has been UK resident every tax year since. The 2014-15 year counts in full even if it was a split year. By 2023-24 he has 10 years (2014-15 to 2023-24). If he died in 2024-25, the deaths-before-April-2025 rules would apply. If he dies in 2026-27, the 20 years looked at are 2006-07 to 2025-26, of which he was resident in 12. He is a long-term UK resident, and his Nigerian assets are in scope.
What comes into scope, with numbers
GOV.UK sets the standard threshold at £325,000, with 40% charged above it. The threshold can rise to £500,000 if a home is left to children or grandchildren, and what you leave to a spouse or civil partner is generally exempt. Once you are long-term resident, everything you own anywhere counts towards that threshold.
| Example estate (single person, no home to children) | Not long-term resident | Long-term resident |
|---|---|---|
| UK flat | £280,000 | £280,000 |
| Land in Ibadan (sterling value at death) | Outside UK IHT | £70,000 |
| Naira savings in Lagos (sterling value) | Outside UK IHT | £15,000 |
| Estate counted | £280,000 | £365,000 |
| Above £325,000 | £0 | £40,000 |
| Tax at 40% | £0 | £16,000 |
The figures are an illustration. The point is that a modest Nigerian portfolio can tip an estate over the threshold once the residence test is met. The value used for Nigerian property is its market value at death converted into pounds, and a valuation from a Nigerian estate surveyor with the date and rate used is the evidence executors will need. For more on Nigerian assets in the estate, see UK inheritance tax on Nigerian assets.
If you leave the UK: the tail
Leaving does not end long-term residence straight away. IHTM47020 sets out a tail:
| Tax years of UK residence | Tax years you stay in scope after leaving |
|---|---|
| 10 to 13 | 3 |
| 14 | 4 |
| 15 | 5 |
| Each further year | One more |
| 20 or more | 10 (the maximum) |
HMRC's examples include someone with 15 of the last 20 years remaining in scope for 5 years after leaving, and someone with 30 years in the UK remaining in scope for the full 10. The years of non-residence must be consecutive. After 10 consecutive years of non-residence you are not treated as long-term resident even if you come back, and the count starts again. Royal London's adviser note (29 December 2025) describes the same 3-to-10-year tail. For a planned move home, read when Nigerian tax starts on a returnee alongside this.
Gifts while you are alive
The same status matters for lifetime gifts. HMRC's manual on people who are not long-term residents (IHTM47030) treats the transferor's status immediately before the transfer as the test, so a gift of Nigerian land made before you reach 10 years is outside UK inheritance tax, while the same gift made after is a potentially taxable gift under the seven-year rule. See gifting Nigerian land to a child, which also covers the capital gains tax side.
What to check first
- List each tax year since you arrived and whether you were UK resident in it.
- Count how many of the last 20 were UK resident years.
- List Nigerian assets with an approximate sterling value and how the value was found.
- If you plan to leave, work out how many tax years the tail would last.
- Make or update wills in both countries so executors know what exists and where.
Questions people ask
Does UK inheritance tax apply to my land in Nigeria?
Yes, if you are a long-term UK resident when you die, meaning UK resident for at least 10 of the previous 20 tax years. If you are not, only your UK assets are taxed.
Does my Nigerian domicile still protect me from UK inheritance tax?
Not for deaths and gifts from 6 April 2025. HMRC's test now applies regardless of domicile and is based on years of UK residence.
How long does UK inheritance tax follow me after I move back to Nigeria?
Between 3 and 10 tax years. Ten to 13 years of UK residence gives 3 years; each further year adds one, up to 10 for 20 or more years.
Does a split year count towards the 10 years?
Yes. HMRC's manual says a split year counts as a full year of UK residence for the long-term residence test.
Sources
- HMRC Inheritance Tax Manual IHTM47020: long-term UK residence test (updated 7 Apr 2026) · accessed Oct 2026
- HMRC Inheritance Tax Manual IHTM47030: not a long-term UK resident (updated 7 Apr 2026) · accessed Oct 2026
- GOV.UK: Inheritance Tax when someone living outside the UK dies · accessed Oct 2026
- GOV.UK: Inheritance Tax (updated 30 Sep 2026) · accessed Oct 2026
- Royal London: Long-term resident and Inheritance Tax (29 Dec 2025) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.