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.

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