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Advising Divorced Clients on Estate Planning: Financial and Legal Considerations

· 20 min

Executive Summary

Divorce is the single most disruptive event for an existing estate plan, yet the advisory response remains frequently fragmented across legal, financial, and pension disciplines. With 102,678 divorces granted in England and Wales in 2023 -- 74.2% under the no-fault framework -- the scale of post-divorce estate planning need is substantial. This article provides a systematic five-domain framework for IFAs: wills, pension death benefit nominations, inheritance tax position, capital gains tax transfers, and residual claims risk under the Inheritance (Provision for Family and Dependants) Act 1975. The analysis integrates the residence-based IHT regime operational from April 2025 and the proposed pension death benefit IHT inclusion from April 2027, both of which materially alter the post-divorce planning calculus. Consumer Duty obligations under PRIN 2A reinforce that comprehensive post-divorce review is a regulatory expectation, not a discretionary service enhancement.

1. The Scale and Complexity of Post-Divorce Estate Planning

The Office for National Statistics recorded 102,678 divorces in England and Wales in 2023, with 74.2% processed under the no-fault framework introduced by the Divorce, Dissolution and Separation Act 2020 (DDSA 2020).12 The median duration of marriages ending in divorce stood at 12.7 years for opposite-sex couples, indicating that the majority of divorcing clients will have accumulated meaningful estate planning structures -- wills, pension nominations, joint property arrangements, and protection policies -- all of which require coordinated review following a final order.

Divorce triggers consequences across five distinct domains that collectively constitute the estate plan: testamentary provisions (wills and intestacy), pension death benefit nominations, the inheritance tax position (including nil rate band transferability), capital gains tax treatment of asset transfers, and residual claims risk under the Inheritance (Provision for Family and Dependants) Act 1975. The challenge for advisers is that these domains are governed by different statutes, administered by different professional disciplines, and subject to different timelines -- yet they interact in ways that demand a unified advisory response.3

The FCA explicitly identifies relationship breakdown as a life event that may render a consumer vulnerable under FG21/1.4 Consumer Duty obligations (PRIN 2A, effective July 2023) require firms to deliver good outcomes for all retail customers, with heightened expectations for those in vulnerable circumstances.5 An adviser conducting a post-divorce portfolio review without addressing the estate planning cascade -- pension nominations that still name a former spouse, a will that no longer operates as intended, an IHT position transformed by loss of the spousal exemption -- risks delivering incomplete outcomes for a client the regulator regards as potentially vulnerable.

The four Consumer Duty outcomes -- products and services, price and value, consumer understanding, and consumer support -- each have direct application in the post-divorce context. Products may require reassessment (revised protection needs as a single person), fee structures may warrant review (more complex planning needs justifying enhanced service), communication must accommodate emotional and financial complexity, and the support model should recognise that divorced clients may be making significant financial decisions during a period of heightened stress.5

The DDSA 2020 introduced a minimum 26-week timeline from application to final order (20-week reflection period plus six weeks to conditional order becoming final), during which the estate plan remains in its pre-divorce state.2 This window presents both a risk (clients may assume estate planning matters resolve automatically on divorce) and an opportunity (advisers can coordinate the post-divorce restructuring in advance of the final order taking effect). Proactive engagement during this period -- alerting clients to the estate planning consequences that will crystallise on the final order -- represents a tangible service differentiator within the advisory relationship.

2. Wills, Intestacy, and the Section 18A Trap

Section 18A of the Wills Act 1837 provides that where a testator's marriage is dissolved or annulled, provisions appointing the former spouse as executor or trustee take effect as if the former spouse had died on the date of dissolution, and property devised or bequeathed to the former spouse passes as if they had died on that date -- except where a contrary intention appears in the will.6 This deemed-death provision was inserted by the Administration of Justice Act 1982, substituted by the Law Reform (Succession) Act 1995, and updated terminologically by the DDSA 2020 (replacing "decree absolute" with "final order" throughout).

The statutory protection, however, is narrower than many clients and some advisers appreciate. Section 18A does not revoke the will; it removes the former spouse from its operative provisions. The consequences depend entirely on the will's drafting. Where the former spouse was the sole residuary beneficiary and no substitutional gift was included, the residuary estate falls into partial intestacy -- distributed under the intestacy rules in the Administration of Estates Act 1925, which may direct assets to persons the testator did not intend to benefit, or distribute them in proportions inconsistent with the client's post-divorce intentions.7

Consider a common scenario: a will leaves the entire estate to "my spouse" with no named substitutes. On divorce, s.18A deems the former spouse to have predeceased. If the testator has children, the estate passes to them under intestacy -- but subject to the statutory trusts under the Administration of Estates Act 1925, with the first GBP 322,000 (as at July 2023) held absolutely and the remainder on trust until age 18. If the testator has no children, the estate may pass to parents, siblings, or more remote relatives. At no point does the statutory mechanism create the estate plan the divorced client actually requires -- it merely removes one beneficiary from a document drafted in different circumstances.

The position is further complicated where the will contains life interest trusts or discretionary trust provisions that reference the former spouse as a potential beneficiary alongside children. The s.18A deemed-death treatment applies to devises and bequests to the former spouse, but the interaction with broader discretionary trust class definitions may require careful legal analysis -- a matter on which the adviser should prompt the client to obtain specialist probate advice.

The risk is compounded by the Inheritance (Provision for Family and Dependants) Act 1975. A former spouse who has not remarried or formed a new civil partnership retains standing to apply for financial provision from the deceased's estate under s.1(1)(b) of the 1975 Act.8 The court applies a maintenance standard rather than the wider provision available to a surviving spouse, but the claim itself introduces litigation risk and delay in the administration of the estate. Clean break orders under s.15 of the 1975 Act can bar such applications, and are routinely sought in financial remedy proceedings.9 Advisers should verify whether the client's financial consent order included a s.15 bar, as its absence creates an ongoing contingent liability against the estate. This is a matter for verification with the client's solicitor rather than a judgment the adviser should make independently.

The advisory imperative is clear: execution of a new will following divorce is essential, not optional. Reliance on s.18A as a substitute for testamentary planning exposes the client to intestacy-derived distribution, unintended tax consequences, and 1975 Act claims. The adviser's role is to identify the gap, communicate its significance, and facilitate referral to an appropriate solicitor for will drafting.

3. Pension Nominations: The Critical Blind Spot

Unlike testamentary provisions, which receive statutory protection through s.18A of the Wills Act 1837, pension death benefit nominations and expression-of-wish forms have no equivalent automatic revocation mechanism on divorce.10 A former spouse may remain the nominated beneficiary of drawdown pensions, workplace defined contribution schemes, death-in-service benefits, and standalone protection policies unless the member actively updates the nomination.

Expression-of-wish forms are advisory rather than binding on scheme trustees or administrators. In practice, however, trustees almost always follow the most recent nomination when exercising their discretion over death benefit distribution. Where a divorced member has not updated their nomination, the former spouse's name remains the most recent recorded instruction -- creating a practical presumption in their favour that persists regardless of the legal dissolution of the marriage.1011

The pension sharing mechanism itself, established by the Welfare Reform and Pensions Act 1999, ss.28-29, operates separately from the death benefit nomination.12 A pension sharing order on divorce creates a pension debit (reducing the member's benefits) and a pension credit (for the former spouse), expressed as a percentage of the cash equivalent transfer value. Implementation takes up to four months from the order taking effect. However, completion of the pension sharing process does not trigger a review or revocation of the death benefit nomination on the member's residual fund -- the two mechanisms are entirely independent.

The role distinction between a Pension on Divorce Expert (PODE) and an IFA requires careful delineation. The PODE provides an impartial, court-facing valuation and sharing analysis; the IFA advises one party on the financial impact, investment strategy, and ongoing planning. These roles cannot be combined for the same case, as the Pension Advisory Group (PAG) guidelines make clear.1314 However, it is the IFA -- holding oversight of the client's pension arrangements post-divorce -- who is best positioned to identify that death benefit nominations require updating.

The scope of the nomination audit should extend beyond the client's main pension arrangements. Many clients accumulate multiple workplace pension schemes over a career, and older arrangements may have been forgotten or consolidated without updating the associated death benefit nomination. Group life policies provided through current or former employers, standalone protection policies, and any pension arrangement subject to a pension sharing order (where the member retains a residual fund) must all be reviewed. The adviser should request that the client compile a comprehensive list of all pension and protection arrangements, cross-referencing this against the information held on file.

The April 2027 Inflection Point

Subject to the Finance (No.2) Bill 2025-26 completing its parliamentary passage, from 6 April 2027 unused pension funds and death benefits are to be included within the member's estate for IHT purposes.15 The spousal and civil partner exemption is maintained, but this applies exclusively to current spouses and civil partners -- not former spouses. A deceased member whose expression-of-wish form still names a former spouse may therefore generate IHT liability on the pension fund value passing to a non-exempt beneficiary. The recipient also faces income tax on the pension death benefit, creating a potential combined effective tax rate that could exceed 60%.16

To illustrate: a divorced client aged 55 dies with a GBP 500,000 SIPP, the expression-of-wish form still naming the former spouse. Under the current rules (pre-April 2027), the former spouse receives the pension fund free of IHT (pensions sit outside the estate) and income tax-free if the member died before age 75. Under the proposed April 2027 rules, the GBP 500,000 would enter the IHT estate, and if it passes to the former spouse (a non-exempt beneficiary), IHT of up to GBP 200,000 (at 40%) may apply. The former spouse also faces income tax on the benefit received. By contrast, had the nomination been updated to name the client's adult children, the same fund would face IHT but avoid the double taxation that arises from passing through a non-exempt beneficiary who is also subject to income tax on the receipt.

The July 2025 consultation response indicated that personal representatives, rather than scheme administrators, are to bear responsibility for reporting and paying IHT on pension death benefits.15 This administrative framework reinforces the importance of accurate nomination records: personal representatives managing the estate of a divorced individual will need to identify all pension arrangements and verify the current nomination status as part of the IHT reporting process.

For divorced clients, the proposed April 2027 change transforms nomination review from a matter of distributional preference into a tax-critical action. A systematic audit across all pension and protection arrangements -- including workplace schemes, personal pensions, self-invested personal pensions, and group life policies -- should be treated as a priority within the post-divorce advisory workflow.

4. The Inheritance Tax Landscape After Divorce

Loss of Transferable Nil Rate Band

IHTM43005 confirms that where a marriage ends by divorce (rather than death), any unused nil rate band on the former spouse's subsequent death is not available for transfer to the other former spouse.17 The current NRB stands at GBP 325,000, frozen until 2029-30. For a married couple, the transferable NRB mechanism provides potential access to a combined GBP 650,000 threshold on the second death. Divorce extinguishes this transferability entirely. Remarriage restores transferability with the new spouse, but the former spouse's unused NRB is permanently lost to the divorced client -- it cannot be recovered or transferred from a previous marriage.

Loss of Transferable Residence Nil Rate Band

The residence nil rate band (GBP 175,000, also frozen until 2029-30) follows the same principle: it is transferable only between spouses or civil partners whose relationship ended by death.18 Divorced clients planning to leave property to direct descendants can claim their own RNRB but cannot benefit from a former spouse's unused allowance. The combined loss -- up to GBP 1,000,000 in effective IHT-free threshold for a married couple (GBP 325,000 + GBP 175,000 multiplied by two) reduced to a maximum GBP 500,000 for a single divorced individual -- represents a material shift in estate tax exposure.

RNRB Downsizing Addition

Where a divorced client lost their share of the former matrimonial home as part of the financial settlement on or after 8 July 2015, the downsizing addition may apply. This provision allows a claim where an individual has disposed of a qualifying residential interest and subsequently acquired a less valuable property or ceased to own a home entirely, provided other assets of equivalent value pass to direct descendants on death.19 The downsizing addition can preserve RNRB entitlement that would otherwise be lost -- a consideration that advisers managing post-divorce financial restructuring should evaluate. The claim is made by the personal representatives on form IHT435 and requires careful documentation of the disposal circumstances and the value of assets passing to qualifying beneficiaries.

Spouse Exemption and Court-Ordered Transfers

IHT spouse exemption under IHTA 1984, s.18 applies only to transfers between persons who are married or in a civil partnership at the time of transfer. The exemption ceases at the point of final order.20 However, transfers made pursuant to court orders under the Matrimonial Causes Act 1973 receive separate protection. HMRC's analysis, confirmed in Haines v Hill [2007] EWCA Civ 1284, is that a court-ordered financial settlement on divorce does not diminish the transferor's estate (the court merely quantifies existing entitlements), so the basic IHT charging provisions are not engaged. IHTA 1984, s.10 provides additional protection, treating such dispositions as not being transfers of value where no gratuitous benefit was intended.21 Advisers should note that properly structured divorce settlements do not, therefore, trigger IHT -- but only where the transfer is made pursuant to a court order or formal agreement. Informal post-divorce transfers between former spouses, made outside the scope of a court order, do not benefit from this protection and may constitute potentially exempt transfers or chargeable lifetime transfers depending on their nature.

Residence-Based IHT Regime: Implications for Mobile Clients

The residence-based IHT regime, enacted by the Finance Act 2025 and operational from 6 April 2025, replaced the domicile-based system with a 10-out-of-20-year long-term resident test and 3-10 year tail provisions.22 For divorced clients who relocate internationally following a financial settlement -- a pattern common among internationally mobile families -- the tail provisions create continued UK IHT exposure for up to 10 years after departure, depending on the length of prior UK residence.

An individual who has been UK-resident for 20 or more of the preceding 20 tax years will remain within the IHT net for 10 years following departure; shorter residence periods produce correspondingly shorter tails. Where divorce prompts a return to a country of origin or relocation for professional reasons, the adviser must assess how the tail period interacts with the client's post-divorce asset base, including any UK property retained as part of the financial settlement. This interaction between the residence-based regime and post-divorce planning is a new layer of complexity that did not exist under the former domicile-based system. The adviser should also consider the implications for any excluded property trusts established prior to April 2025, which may have been restructured as part of the divorce settlement.

Quantifying the IHT Exposure Differential

To illustrate the practical impact, consider a married couple with a combined estate of GBP 2,000,000, including a qualifying residential property. While married, the estate benefits from a combined IHT-free threshold of GBP 1,000,000 (two NRBs at GBP 325,000 plus two RNRBs at GBP 175,000), producing an IHT liability on the second death of approximately GBP 400,000 at 40%. Following divorce, each former spouse's estate is assessed independently. Assuming an equal division, each holds GBP 1,000,000 with a single NRB (GBP 325,000) and a single RNRB (GBP 175,000 if qualifying conditions are met), producing an IHT-free threshold of GBP 500,000 per individual. The combined IHT liability across both estates rises to GBP 400,000 -- the same total, but now crystallising on the first death rather than being deferred to the second. The loss of deferral through the spousal exemption is itself a significant liquidity event for the estate, potentially requiring assets to be sold to meet the IHT liability within the six-month payment deadline.

5. Capital Gains Tax Planning on Separation and Divorce

The Finance Act 2023 materially improved the CGT treatment of asset transfers between separating spouses.23 Prior to 6 April 2023, the no-gain-no-loss window closed at the end of the tax year of separation -- a rule that could force CGT crystallisation within months or even weeks of a couple ceasing to cohabit. The revised framework provides three distinct treatments.

First, separating spouses have until the end of the third tax year after the year in which they cease to live together to make no-gain-no-loss transfers. This extended window accommodates the reality that divorce proceedings and financial settlements frequently extend well beyond the initial separation date.

Second, transfers made under a formal divorce agreement or pursuant to a court order attract no-gain-no-loss treatment without time limit. This provision eliminates CGT risk from court-ordered financial settlements entirely, regardless of when the transfer is executed relative to separation.

Third, special rules apply to the former family home. Where one spouse retains an interest in the property under a Mesher order or similar arrangement, and the home is sold at a later date, private residence relief remains available provided the conditions of TCGA 1992 are met.23 This is particularly relevant where a court order grants one spouse the right to occupy the property until children reach a specified age, with a deferred sale and division of proceeds thereafter.

For advisers managing investment portfolios during the separation period, these rules have direct operational implications. The timing of asset transfers between spouses must be coordinated with the broader financial settlement to ensure that no-gain-no-loss treatment is available. Where the adviser holds discretionary management authority, particular care is needed to avoid triggering disposals within jointly held portfolios during the transition period. The three-year window provides meaningful planning capacity, but it requires active management rather than passive reliance on the statutory default. Advisers should document the date of separation carefully, as this determines when the three-year clock begins -- and disputed separation dates can create uncertainty about the availability of no-gain-no-loss treatment.

The interaction between CGT base cost and IHT planning also warrants consideration. Assets transferred on a no-gain-no-loss basis retain the original base cost, meaning the receiving spouse inherits the latent gain. Where the receiving spouse subsequently dies, the uplift in base cost on death (TCGA 1992, s.62) eliminates the gain -- a factor that may influence the allocation of assets with significant embedded gains within the divorce settlement, particularly for older clients with terminal or serious health conditions.

Conclusion

Post-divorce estate planning demands a coordinated response across five domains: wills, pension death benefit nominations, IHT position, CGT transfers, and residual claims risk under the I(PFD)A 1975. The statutory protections available -- s.18A of the Wills Act 1837 for testamentary provisions and the extended CGT no-gain-no-loss window under the Finance Act 2023 -- provide partial safeguards, but neither constitutes an adequate substitute for comprehensive advisory intervention.

The IFA occupies a unique coordination role because the assets most affected by divorce -- investment portfolios, pension arrangements, and protection policies -- are the very assets over which the adviser holds direct oversight. The pension nomination blind spot is the single most dangerous gap in current post-divorce practice, and the proposed April 2027 inclusion of pension death benefits within the IHT estate, subject to the Finance (No.2) Bill 2025-26 receiving Royal Assent, elevates this from a distributional concern to a tax-critical liability.

The residence-based IHT regime (operational from April 2025) introduces a further dimension for internationally mobile clients, whose post-divorce relocation decisions now carry IHT consequences through the tail provisions that can persist for up to a decade. The loss of transferable NRB and RNRB, the cessation of the spousal exemption, and the potential for 1975 Act claims from a former spouse who has not remarried collectively underscore that divorce does not merely alter an estate plan -- it dismantles it.

Consumer Duty obligations reinforce that this is a regulatory expectation. Divorced clients are clients in vulnerable circumstances; a post-divorce review that omits the estate planning dimension is an incomplete service outcome. Advisers who establish a systematic five-domain review process position themselves both to meet their regulatory obligations and to deliver measurable value at a critical juncture in the client relationship.

CPD Declaration

Estimated Reading Time: 22 minutes Technical Level: Advanced Practice Areas: Estate Planning, Divorce Financial Planning, Inheritance Tax, Pension Death Benefits

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the five domains requiring coordinated review following a client's divorce (wills, pension death benefit nominations, IHT position, CGT transfers, and residual claims risk under the I(PFD)A 1975) and explain the statutory framework governing each.
  2. Explain the effect of Wills Act 1837, s.18A on testamentary provisions favouring a former spouse and distinguish why deemed-death treatment does not constitute adequate post-divorce estate planning.
  3. Distinguish between the statutory revocation of will provisions on divorce (s.18A) and the absence of equivalent revocation for pension death benefit nominations, including the implications of the proposed April 2027 pension IHT inclusion.
  4. Calculate the IHT exposure increase resulting from loss of transferable NRB and RNRB on divorce, using the current threshold values (GBP 325,000 NRB and GBP 175,000 RNRB, both frozen until 2029-30).
  5. Evaluate how the residence-based IHT regime (10-out-of-20-year test and 3-10 year tail provisions) interacts with post-divorce international relocation decisions.

Competency Mapping

  • FCA Training and Competence: Estate planning and tax-efficient investment strategies (TC 2.1)
  • CII Accredited CPD: Financial planning, estate planning, and pension planning competency areas
  • Personal Finance Society: Ongoing professional development -- life events and financial planning

Reflective Questions

  1. "What processes does the practice currently have in place to identify clients who have recently divorced and trigger a comprehensive estate planning review across all five domains?"
  2. "How would the practice systematically audit pension death benefit nominations across a client's multiple pension arrangements following a divorce, and what priority framework would apply given the proposed April 2027 deadline?"
  3. "In cases involving internationally mobile divorced clients, how should the adviser assess the interaction between the residence-based IHT tail provisions and the client's post-divorce asset base?"

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. ONS -- Divorces and dissolutions in England and Wales: 2023 (released 2 July 2025). https://www.ons.gov.uk/peoplepopulationandcommunity/birthsdeathsandmarriages/divorce/bulletins/divorcesinenglandandwales/2023 ↩

  2. Divorce, Dissolution and Separation Act 2020 c.11. https://www.legislation.gov.uk/ukpga/2020/11 ↩ ↩2

  3. FCA Finalised Guidance FG22/5 -- Consumer Duty (July 2022). https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf ↩

  4. FCA Finalised Guidance FG21/1 -- Guidance for firms on the fair treatment of vulnerable customers (February 2021, updated March 2025). https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf ↩

  5. FCA Finalised Guidance FG22/5 -- Consumer Duty (July 2022), PRIN 2A outcomes framework. https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf ↩ ↩2

  6. Wills Act 1837, s.18A -- Effect of dissolution or annulment of marriage on wills. https://www.legislation.gov.uk/ukpga/Will4and1Vict/7/26/section/18A ↩

  7. Administration of Estates Act 1925, Part IV -- Distribution of residuary estate. https://www.legislation.gov.uk/ukpga/Geo5/15-16/23/part/IV ↩

  8. Inheritance (Provision for Family and Dependants) Act 1975, s.1(1)(b). https://www.legislation.gov.uk/ukpga/1975/63 ↩

  9. Inheritance (Provision for Family and Dependants) Act 1975, s.15. https://www.legislation.gov.uk/ukpga/1975/63/section/15 ↩

  10. Royal London for Advisers -- Death benefits: nominate a beneficiary. https://adviser.royallondon.com/technical-central/pensions/death-benefits/death-benefits-discretion-and-how-to-nominate-a-beneficiary/ ↩ ↩2

  11. Welfare Reform and Pensions Act 1999, ss.28-29 -- Pension sharing mechanism. https://www.legislation.gov.uk/ukpga/1999/30/part/IV/chapter/I/crossheading/pension-sharing-mechanism ↩

  12. Welfare Reform and Pensions Act 1999, s.29 -- Implementation period. https://www.legislation.gov.uk/ukpga/1999/30/section/29 ↩

  13. MoneyHelper -- How to split pensions in a divorce or dissolution. https://www.moneyhelper.org.uk/en/pensions-and-retirement/pension-problems/split-pensions-in-a-divorce-or-dissolution ↩

  14. Pension Advisory Group -- A Guide to the Treatment of Pensions on Divorce (2nd edition, 2019). https://www.nuffieldfjo.org.uk/resource/pension-advisory-group-report ↩

  15. GOV.UK -- Inheritance Tax on unused pension funds and death benefits. https://www.gov.uk/government/publications/reforming-inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-on-unused-pension-funds-and-death-benefits ↩ ↩2

  16. Royal London for Advisers -- IHT: pension death benefits from April 2027. https://adviser.royallondon.com/technical-central/pensions/death-benefits/inheritance-tax-on-pension-death-benefits-from-april-2027/ ↩

  17. HMRC Inheritance Tax Manual -- IHTM43005: Divorce or dissolution of a civil partnership. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43005 ↩

  18. GOV.UK -- Work out and apply the residence nil rate band for Inheritance Tax. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩

  19. HMRC IHT435 -- Claim for residence nil rate band (RNRB), downsizing addition. https://assets.publishing.service.gov.uk/media/67ee9503e9c76fa33048c768/claim-for-residence-nil-rate-band-iht435.pdf ↩

  20. HMRC Inheritance Tax Manual -- IHTM11032: Spouse or civil partner exemption. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm11032 ↩

  21. HMRC Inheritance Tax Manual -- IHTM04173: Dispositions for maintenance of the transferor's family; Haines v Hill [2007] EWCA Civ 1284. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04173 ↩

  22. Finance Act 2025, Part 3 -- Inheritance Tax (residence-based regime). https://www.legislation.gov.uk/ukpga/2025/8/part/3/crossheading/inheritance-tax ↩

  23. GOV.UK -- Capital Gains Tax: separation and divorce (updated rules from 6 April 2023). https://www.gov.uk/government/publications/capital-gains-tax-transfers-of-assets-between-spouses-and-civil-partners-in-the-process-of-separating/capital-gains-tax-separation-and-divorce ↩ ↩2

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