RNRB Claim Where Deceased Was Non-Domiciled

[remia (Remi Aiyela)]

Does anyone have experience of claiming RNRB on UK property where the deceased was domiciled abroad? In the case I am dealing with, the deceased had a UK residential property where he stayed on visits to the UK but was both non-resident and non-domiciled. His UK property goes to his children. Will HMRC argue that claiming RNRB means we cannot also maintain that the deceased was non-resident and non-domiciled? We wish to avoid any suggestion that the deceased was resident in the UK.

Any experience of this? How did you deal with it?

Many thanks.

[MalcFinney (Malcolm Finney)]

@remia

His UK property goes to his children. Will HMRC argue that claiming RNRB means we cannot also maintain that the deceased was non-resident and non-domiciled?

There is nothing inconsistent about claiming the RNRB whilst being non-resident and non-domiciled. The property must, inter alia, qualify as a residence which should be possible by still not falling to be treated as UK resident under the SRT.

Malcolm Finney