[IHTM11033] IHTM11033 – Spouse or civil partner exemption: spouse or civil partner domiciled outside UK
Where, immediately before the transfer
•the transferor is domiciled (IHTM13031) in the United Kingdom, or is treated as domiciled in the UK under IHTA84/S267, but
•the transferor's spouse or civil partner (IHTM11032) is neither domiciled nor treated as domiciled in the United Kingdom
the exemption for transfers between spouses and civil partners is restricted. Where the transfer is on or after 6 April 2013, the exemption is limited to the nil-rate band that applies at the date of the transfer.