The residence and domicile conditions

In order for the POAT to apply to the individual for any tax year, they must be resident in the UK during that year, see the Residence ― overview guidance note.

Where the individual is UK resident but is domiciled outside the UK (before 6 April 2025), or is UK resident but is not a long-term UK resident (6 April 2025 onwards), the POAT applies only if the asset is situated in the UK.

Before 6 April 2025, any property in an excluded property settlement (that is, property outside the UK settled by a non-domiciled settlor)