For the latest New Developments, see ND.2621 and ND.2751.
Transfers between spouses (or civil partners) where the transferor is UK domiciled but the transferee spouse is not, benefit from a limited spousal exemption.
For transfers on or after 6 April 2013 exempt transfers of up to the nil rate band (currently £325,000) can be made from a UK domiciled transferor to their non-UK domiciled spouse1. The exemption is linked to the nil rate band and will change accordingly.
As to the meaning of domicile, see I9.201.
The limit is before grossing but with a deduction for any amount previously taken into account for the purpose of the exemption (it is a lifetime allowance and is not refreshed like the nil rate band).
For transfers before 6 April 2013 (and after 9 March 1982), the limit was £55,0002.
Once the exemption limit has been reached there is the possibility of a transfer to a non-domiciled spouse being a potentially exempt transfer (PET). It should be noted
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