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Equity Release and Estate Planning: Advising Clients on Implications and Strategies

· 20 min

Executive Summary

The equity release market reached GBP 2.57 billion in 2025, growing 11% year-on-year against a backdrop of frozen inheritance tax thresholds, the residence-based IHT regime enacted from 6 April 2025, and the confirmed inclusion of pension death benefits within IHT from April 2027. Lifetime mortgages create deductible liabilities under IHTA 1984, but the debt deduction restrictions in section 175A, the residence nil-rate band erosion caused by encumbered property values, and the section 162B interaction with relievable property introduce material complexity. The FCA's intensifying scrutiny of later life lending -- evidenced by multi-firm review findings, the FS25/6 Mortgage Rule Review, and Consumer Duty expectations -- demands demonstrably holistic suitability analysis. This article provides a technical framework enabling later life advisors and IFAs to navigate the intersection of IHT debt deduction law, RNRB quantification, pension reform strategy, and regulatory compliance.

1. The Equity Release Market in Context

Market Growth and Demand Drivers

The Equity Release Council reported total lending of GBP 2.57 billion across 2025, an 11% increase from GBP 2.3 billion in 2024, with Q1 2025 alone generating GBP 665 million -- a 32% year-on-year increase.1 The average release in Q4 2025 stood at GBP 123,174, up 5.7% year-on-year, while product availability expanded to 1,669 lifetime mortgage products by end of Q2 2025.2 Customer usage data reveals that 26% of releases funded existing mortgage repayment, 21% funded home improvements, and 13% were directed toward gifting to family members -- this latter figure carrying particular estate planning significance.3

Several structural factors underpin continued growth. The nil-rate band has remained frozen at GBP 325,000 since April 2009, and the residence nil-rate band at GBP 175,000 since April 2020, with both now confirmed frozen until at least April 2031.4 Over-55s hold approximately GBP 2.6 trillion in property wealth out of a total UK housing stock valued at GBP 9.1 trillion.5 With 80% of advisors forecasting increased lending in 2026, the market trajectory appears firmly upward.6

The average APR on new lifetime mortgage products stood at 7.24% in Q2 2025, up from 6.64% in Q2 2024.2 This rate environment has a compounding significance for estate planning: higher interest rates accelerate the erosion of property equity over time, magnifying both the debt deduction benefit and the residence nil-rate band cost -- a tension explored in detail in subsequent sections.

ERC Standards 2.0 and Consumer Protections

The Equity Release Council launched Standards 2.0 on 6 May 2025, following input from eight industry working groups.7 The refreshed framework introduces a sixth product standard: a long-term care ERC waiver that extends beyond formal care home admission to cover care provided by relatives, subject to medical certification. The existing five standards -- fixed or capped interest rates for the life of the loan, the home-for-life guarantee, portability, the no-negative-equity guarantee, and voluntary repayment options -- remain unchanged.8

Standards 2.0 also introduced the ERC Consumer Charter, setting out assurances of a tailored, transparent, and outcome-focused process.9 For practitioners, the significance extends beyond consumer protection: Standards 2.0 establishes the baseline against which the FCA will assess product governance and fair value obligations under the Consumer Duty. The sixth standard on long-term care is particularly relevant to estate planning, as entry into care is a common trigger event for lifetime mortgage repayment and can interact with means-testing thresholds in ways that affect the estate's residual value.

The Residence-Based IHT Regime

The Finance Act 2025 enacted the residence-based IHT regime from 6 April 2025, replacing the longstanding domicile-based system.10 Individuals resident in the UK for 10 out of 20 tax years are now subject to IHT on worldwide assets, with 3-to-10-year tail provisions applying on departure. For equity release planning, this reform is primarily relevant where clients hold international property assets or have recently established UK residence. The interaction between lifetime mortgage debt secured against UK property and non-UK estate assets warrants specialist cross-border advice -- a topic addressed in detail in separate cross-border estate planning guidance.11

2. IHT Debt Deduction Mechanics

The Section 175A Framework

The deductibility of lifetime mortgage debt at death is governed by IHTA 1984, section 175A, inserted by Finance Act 2013, Schedule 36, paragraph 4, and subsequently amended by Finance Act 2014, section 117.12 Section 175A establishes two conditions under which a liability may be deducted from the deceased's estate:

Condition 1 (s.175A(1)(a)): The liability is actually discharged from the estate after death, in money or money's worth. For a standard lifetime mortgage, this condition is met where the personal representatives repay the lender from the sale proceeds of the property or from other estate assets.

Condition 2 (s.175A(2)): Where the liability is not discharged after death, it may still be deducted provided: (a) there is a "real commercial reason" for non-discharge; and (b) securing a tax advantage is not the main purpose, or one of the main purposes, of leaving it undischarged.

The "real commercial reason" test under section 175A(3) is satisfied where the liability is owed to a person dealing at arm's length, or where an arm's length creditor would not require discharge in the circumstances.13 For standard lifetime mortgages from ERC-member lenders, this test is generally met -- the lender's contractual terms do not require repayment until death, entry into long-term care, or sale of the property. HMRC guidance at IHTM28029 confirms the approach to investigating non-repayment of liabilities under these provisions.14

Practitioners should note that the "tax advantage" limb of section 175A(2)(b) is a subjective purpose test. Where the primary motivation for taking equity release is demonstrably to reduce IHT -- rather than to fund retirement needs, gifting, or home improvements -- HMRC could argue that securing a tax advantage was the main purpose, or one of the main purposes, of leaving the liability undischarged. Robust file documentation of the client's non-tax motivations is therefore essential, even where the arm's length condition is satisfied.

Practical Application: The Arm's Length Lender

Consider a client aged 70 who takes a lifetime mortgage of GBP 200,000 at 7.24% APR from an ERC-member lender. At death 12 years later, the rolled-up balance stands at approximately GBP 464,000. The personal representatives sell the property and repay the lender.

Under section 175A(1)(a), the GBP 464,000 liability is deductible because it is discharged from the estate. The full balance -- including compound interest -- reduces the taxable estate. At 40% IHT, this generates a tax saving of approximately GBP 185,600 on the debt deduction alone.

However, this analysis is incomplete without considering what happened to the released funds, whether the property value still supports the residence nil-rate band, and whether the client's overall estate position improved or deteriorated. These factors are addressed in subsequent sections.

The Section 162B Trap: Relievable Property

Where equity release proceeds are used to acquire assets qualifying for business property relief or agricultural property relief, section 162B of IHTA 1984 requires the debt to be allocated first against the relievable property.15 This creates a direct conflict: the relief that would have exempted the asset from IHT is effectively consumed by the debt allocation.

A client who releases GBP 150,000 of equity and invests in an AIM portfolio qualifying for BPR faces a material risk. If the AIM portfolio is worth GBP 180,000 at death (assuming growth), section 162B requires the GBP 150,000 debt to be deducted against the BPR-qualifying asset first. The BPR only applies to the net value of GBP 30,000, rather than the full GBP 180,000. The "planning" has effectively wasted GBP 150,000 of BPR -- at 40% IHT, a cost of GBP 60,000.16

Advisors recommending equity release where the client intends to invest in relievable property must model the section 162B interaction explicitly. HMRC guidance at IHTM10365 addresses the treatment of mortgages and secured loans as deductions, and practitioners should cross-reference this with the BPR/APR provisions.17 The grandfathering rule for loans taken before 6 April 2013 does not apply to new equity release arrangements, making this a live risk for all current planning.

3. Residence Nil-Rate Band Erosion: The Overlooked Cost

How Lifetime Mortgage Debt Reduces the RNRB

The residence nil-rate band, introduced by Finance Act 2016 (sections 8D-8M), provides an additional GBP 175,000 allowance per person where a qualifying residential interest passes to direct descendants on death.18 Critically, the RNRB applies to the net value of the qualifying residential interest -- that is, the property value after deduction of any encumbrances, including lifetime mortgage debt. HMRC's IHT435 claim form confirms this net-value basis.19

This creates a planning tension that is frequently underappreciated. A lifetime mortgage simultaneously generates a deductible liability (reducing the taxable estate) and erodes the RNRB (potentially increasing the effective IHT rate on the remaining estate). The net benefit depends on whether the debt deduction value exceeds the RNRB loss.

Quantified Scenario: The Compound Interest Problem

Consider a married couple, both aged 68, owning a property valued at GBP 600,000. One spouse takes a lifetime mortgage of GBP 200,000 at 7% APR.

At inception:

  • Net property value: GBP 400,000
  • RNRB available to surviving spouse on second death: GBP 175,000 (individual) or GBP 350,000 (combined with transferable RNRB)
  • Combined RNRB is fully available as net property value (GBP 400,000) exceeds GBP 350,000

After 15 years (both spouses aged 83), assuming no property growth:

  • Rolled-up mortgage balance at 7%: approximately GBP 551,800
  • Net property value: GBP 600,000 minus GBP 551,800 = GBP 48,200
  • Combined RNRB available: capped at GBP 48,200 (net property value)
  • RNRB lost: GBP 350,000 minus GBP 48,200 = GBP 301,800
  • IHT cost of lost RNRB: GBP 301,800 at 40% = GBP 120,720

Debt deduction benefit:

  • GBP 551,800 deductible from estate at 40% = GBP 220,720 IHT saved

Net benefit: GBP 220,720 minus GBP 120,720 = GBP 100,000

The net benefit is substantially less than the headline debt deduction figure suggests. Had the released funds been spent (reducing the estate by GBP 200,000 directly), the total IHT reduction through both debt deduction and expenditure would be clearer -- but the RNRB erosion still applies to the remaining debt balance. Advisors must present this net figure to clients, not the gross debt deduction, to comply with the Consumer Duty's consumer understanding outcome.

The RNRB Taper for Larger Estates

For estates exceeding GBP 2 million, the RNRB is tapered at GBP 1 for every GBP 2 above the threshold, meaning the combined RNRB of GBP 350,000 is entirely eliminated at estates of GBP 2.7 million.20 In these cases, the RNRB erosion from equity release is moot -- the band would have been lost to tapering regardless. Advisors should model the estate's position relative to the GBP 2 million threshold before incorporating RNRB into the planning calculus. Conversely, where equity release reduces the estate below GBP 2 million, the RNRB taper partially or fully unwinds, potentially creating a net positive interaction that offsets the encumbrance-related erosion.

Downsizing Provisions: Limited Applicability

Finance Act 2016, sections 8FA-8FE, introduced downsizing provisions intended to preserve the RNRB where a qualifying residential interest is disposed of on or after 8 July 2015, provided direct descendants inherit assets of equivalent value.21 Whether HMRC treats a lifetime mortgage as a "disposal" of part of the qualifying residential interest (potentially triggering the downsizing addition) or merely as an encumbrance reducing net value is not definitively resolved in published guidance. HMRC acknowledges that the downsizing rules are "complicated," and practitioners should document their analysis and consider seeking advance clearance in marginal cases.22

4. The April 2027 Pension Intersection

Confirmed Reform: Pensions Within IHT

From 6 April 2027, unused pension funds and pension death benefits will be included within the deceased's estate for IHT purposes.23 Personal representatives will be responsible for reporting and paying IHT on pension wealth. The government's impact assessment estimates that of approximately 213,000 estates with inheritable pension wealth in 2027-28, 10,500 will face a new IHT liability and 38,500 will pay more IHT than previously, with an average additional liability of approximately GBP 34,000.24 Spousal exemption is preserved, and death-in-service benefits are excluded from the charge.

Pre-April 2027: The Pension Preservation Rationale

Until April 2027, the conventional planning strategy has been to preserve pension wealth -- which passes outside the estate for IHT purposes -- while using equity release to fund retirement expenditure. The logic is straightforward: drawing housing equity creates a deductible liability (the lifetime mortgage) while keeping pension funds intact in their IHT-exempt wrapper. The equity release debt reduces the taxable estate; the untouched pension passes to beneficiaries free of IHT.

This strategy has been widely promoted and, in the current regime, often delivers a favourable IHT outcome. However, the planning window for this approach is narrowing.

Post-April 2027: Strategic Recalibration

From April 2027, unused pensions become IHT-chargeable. The rationale for preserving pension wealth while drawing housing equity no longer holds automatically.25 Advisors must now model two competing scenarios:

Scenario A -- Draw pension, preserve housing equity:

  • Pension drawdown reduces IHT-chargeable pension wealth
  • Property remains unencumbered, preserving full RNRB
  • No compound interest erosion from lifetime mortgage

Scenario B -- Equity release, preserve pension:

  • Lifetime mortgage creates deductible liability
  • But pension wealth is now also IHT-chargeable
  • Compound interest on lifetime mortgage erodes RNRB
  • Net IHT position depends on relative values and time horizon

Quantified Pension Intersection Example

Consider a single client aged 67 with a GBP 500,000 property, a GBP 300,000 defined contribution pension, and other estate assets of GBP 200,000. The client needs GBP 15,000 per year supplementary income for an estimated 20 years.

Scenario A (post-April 2027): Draw GBP 15,000 per year from pension:

  • Pension depleted by GBP 300,000 over 20 years (ignoring growth for simplicity)
  • Property unencumbered: full RNRB of GBP 175,000 preserved
  • Estate at death (age 87): property GBP 500,000 + remaining pension GBP 0 + other GBP 200,000 = GBP 700,000
  • IHT: (GBP 700,000 minus GBP 325,000 NRB minus GBP 175,000 RNRB) at 40% = GBP 80,000

Scenario B (post-April 2027): Equity release of GBP 150,000 at 7%, preserve pension:

  • Lifetime mortgage after 20 years: approximately GBP 580,700
  • Net property value: GBP 500,000 minus GBP 580,700 = negative (capped at zero by NNEG)
  • RNRB available: GBP 0 (net property value is zero)
  • Pension at death: GBP 300,000 (assuming no growth, no drawdown)
  • Estate: property equity GBP 0 + pension GBP 300,000 + other GBP 200,000 = GBP 500,000
  • IHT: (GBP 500,000 minus GBP 325,000 NRB minus GBP 0 RNRB) at 40% = GBP 70,000

In this simplified illustration, Scenario B produces marginally lower IHT, but the client has lost the entire GBP 175,000 RNRB and the property passes to the lender rather than to descendants. The non-tax consequences -- loss of housing equity inheritance, reliance on the NNEG -- may outweigh the modest IHT saving. This underscores why IHT modelling alone is insufficient; holistic suitability assessment must account for the client's broader objectives and beneficiaries' expectations.

The Gifting Strategy: Using Equity Release to Fund Potentially Exempt Transfers

An emerging strategy involves using equity release to fund PET-qualifying gifts, starting the seven-year clock while simultaneously reducing the estate through the lifetime mortgage debt.26 If the client survives seven years, the gifted funds fall outside the estate entirely, while the lifetime mortgage balance (including compound interest) remains a deductible liability at death.

However, several risks require explicit disclosure. First, the client must survive seven years for the PET to become fully exempt; taper relief applies between three and seven years. Second, the compound interest on the lifetime mortgage continues to grow regardless of the PET outcome. Third, where the gifted funds are used to acquire property that the client subsequently occupies, the pre-owned assets tax charge under Finance Act 2004, Schedule 15 may apply -- creating an ongoing income tax liability that can negate the IHT benefit.27 Fourth, the seven-year cumulation means that if the client makes further chargeable transfers within the period, the available nil-rate band at death is reduced.

5. Regulatory Compliance Framework

MCOB 8: Mandatory Advice and Suitability

FCA Handbook MCOB 8 imposes mandatory advice requirements for equity release transactions.28 Under MCOB 8.6A, execution-only is permitted only after advice has been given and the client has explicitly rejected it. Suitability assessments under MCOB 8.5A must consider the full market, not merely the firm's product panel -- firms cannot recommend the "least worst" product if no suitable option exists within their range.29

For estate planning-motivated equity release, suitability documentation must demonstrate that the advisor considered the IHT implications (including RNRB erosion), the impact of compound interest on the estate, alternative strategies (pension drawdown, downsizing, gifting from income), and the client's broader financial position including care needs.

FCA Multi-Firm Review Findings

The FCA's scrutiny of later life lending has intensified over successive reviews. The June 2020 multi-firm review identified "form-filling approaches" rather than tailored advice, and "order taking" rather than critical suitability examination.30 The September 2023 follow-up found that the FCA was "disappointed" firms had not acted on earlier findings, with continued weaknesses in advice documentation and suitability analysis.31 Nearly 400 financial promotions were removed or amended following these reviews, and sales incentive structures were identified as potentially compromising advice quality.

Consumer Duty and Fair Value

The Consumer Duty (FCA PS22/9) applies to all equity release advice and product manufacture. The FCA's 2025 portfolio letter to lifetime mortgage providers identifies five priority areas: Consumer Duty as the overarching expectation, vulnerability identification and response, intermediary oversight, product design and governance, and fair value assessment through the product lifecycle.32

For advisors, the Consumer Duty's "consumer understanding" outcome is particularly relevant to estate planning discussions. Clients must demonstrably understand that the compound interest on a lifetime mortgage will reduce the value passing to beneficiaries, that the RNRB may be eroded, and that the post-April 2027 pension changes may alter the suitability of the strategy over time. Documentation must evidence this understanding -- not merely record that a conversation occurred.

Means-Tested Care Costs Interaction

Equity release also affects the financial assessment for means-tested social care funding. A lifetime mortgage that reduces property equity below the upper capital limit -- currently GBP 23,250 under the Care Act 2014 -- may bring a client within scope for local authority-funded care, but the assessment methodology and the treatment of encumbered property vary by local authority.33 The delayed social care charging reforms, which proposed raising the upper capital limit to GBP 100,000, remain subject to implementation uncertainty. Advisors must account for the care costs interaction as part of the holistic suitability assessment, particularly given that entry into care is both a common trigger event for lifetime mortgage repayment and a scenario in which remaining property equity directly affects funding eligibility.

The Mortgage Rule Review and Future Direction

The FCA's Mortgage Rule Review (FS25/6, published December 2025) announced a focused market study on later life lending as one of four thematic priorities.34 The review acknowledged capacity constraints: approximately 6,155 certified individuals hold equity release qualifications, but only approximately 2,000 are active advisors, compared with over 35,000 mainstream mortgage advisors.35 Consultations on rule changes are expected from early 2026, with first regulatory changes anticipated later in the year.

The market study will examine whether the current regulatory framework delivers good outcomes for later life borrowers, including whether holistic advice -- encompassing IHT, pension, care funding, and property considerations -- is achievable within the existing MCOB 8 framework or requires structural reform. Practitioners should anticipate potential changes to qualification requirements, suitability documentation standards, and the scope of mandatory advice.

The Holistic Advice Challenge

A persistent structural challenge lies in the regulatory perimeter. MCOB 8 governs equity release advice, but the IHT, pension, and estate planning dimensions fall outside MCOB and require separate permissions and competencies. An advisor with the Certificate in Equity Release (CeRER) is qualified to recommend lifetime mortgages but may lack the tax planning expertise to model RNRB erosion or the pension permissions to advise on drawdown alternatives.36

This creates an advice gap that the FCA has acknowledged but not yet resolved. Best practice requires either cross-qualified individual advisors or formal collaboration between equity release specialists, tax advisors, and estate planners -- with clear documentation of the scope and limitations of each professional's contribution.

Conclusion

Equity release has evolved from a retirement income product into a legitimate estate planning instrument, but the complexity of the surrounding regulatory and tax framework demands a level of technical rigour that much of the existing market literature fails to deliver. The debt deduction mechanics under section 175A, while generally favourable for standard lifetime mortgages from arm's length lenders, must be analysed alongside the RNRB erosion that compound interest generates over time. The section 162B interaction with relievable property creates material traps for clients investing released equity in BPR-qualifying assets.

The confirmed inclusion of pension death benefits within IHT from April 2027 fundamentally alters the strategic calculus. The conventional wisdom of preserving pensions while drawing housing equity requires case-by-case reassessment, and advisors who continue to recommend this approach without modelling the post-2027 position risk both poor client outcomes and regulatory challenge under the Consumer Duty.

The FCA's intensifying focus on later life lending -- through successive multi-firm reviews, the 2025 portfolio letter, and the FS25/6 market study -- signals that regulatory expectations will continue to increase. With only approximately 2,000 active later life advisors serving a market that reached GBP 2.57 billion in 2025, the capacity to deliver genuinely holistic estate planning advice through equity release remains a systemic challenge. Cross-disciplinary collaboration between later life specialists, tax advisors, and estate planners is not merely best practice -- it is becoming a regulatory expectation.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Equity Release, Inheritance Tax Planning, Later Life Lending, Estate Planning

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Evaluate the conditions under which lifetime mortgage debt is deductible under IHTA 1984, section 175A, including the "real commercial reason" test and the "tax advantage" exclusion
  2. Calculate the residence nil-rate band erosion caused by compound interest on a lifetime mortgage and assess its net impact against the debt deduction benefit
  3. Analyse the strategic implications of the April 2027 pension death benefit IHT inclusion for clients with both equity release and pension wealth
  4. Apply FCA Consumer Duty and MCOB 8 suitability requirements to equity release recommendations made within an estate planning context

CII/PFS Competency Mapping

  • R06: Financial Planning Practice -- suitability of later life lending recommendations within holistic financial plans
  • AF5: Financial Planning Process -- advanced estate planning strategies incorporating equity release, IHT, and pension interactions
  • ER1: Equity Release -- regulatory requirements, product suitability, and client outcome assessment

Reflective Questions

  1. How would you document the RNRB erosion analysis when recommending equity release to a client whose estate includes a property valued above GBP 500,000?
  2. What changes to your equity release suitability framework are required to account for the April 2027 pension death benefit IHT inclusion?
  3. How does your firm's referral process ensure that equity release recommendations receive adequate tax planning and estate planning input from appropriately qualified professionals?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 4 February 2026. 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. Equity Release Council, Q3 2025 Lending Figures and Annual Market Data (January 2026). https://www.equityreleasecouncil.com/news/council-publishes-q3-lending-figures-2025/ ↩

  2. Equity Release Council, Market Research Data (2025). https://www.equityreleasecouncil.com/news_type/market-research-data/ ↩ ↩2

  3. Equity Release Council, 2025 Annual Customer Data (January 2026). https://www.equityreleasecouncil.com/news_type/market-research-data/ ↩

  4. HM Government, Inheritance Tax Thresholds. https://www.gov.uk/inheritance-tax ↩

  5. Equity Release Council, Market Research Data (2025). https://www.equityreleasecouncil.com/news_type/market-research-data/ ↩

  6. Equity Release Council, 2025 Annual Market Statistics. https://www.equityreleasecouncil.com/news_type/market-research-data/ ↩

  7. Equity Release Council, Standards 2.0 Launch (6 May 2025). https://www.equityreleasecouncil.com/news/equity-release-council-launches-standards-2-0-with-new-consumer-protections/ ↩

  8. Equity Release Council, Standards 2.0 Launch (6 May 2025). https://www.equityreleasecouncil.com/news/equity-release-council-launches-standards-2-0-with-new-consumer-protections/ ↩

  9. Equity Release Council, Standards 2.0 Launch (6 May 2025). https://www.equityreleasecouncil.com/news/equity-release-council-launches-standards-2-0-with-new-consumer-protections/ ↩

  10. Finance Act 2025, Part 3 -- Inheritance Tax. https://www.legislation.gov.uk/ukpga/2025/8/part/3/crossheading/inheritance-tax ↩

  11. HMRC Trusts and Estates Newsletter (April 2025). https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-april-2025 ↩

  12. Inheritance Tax Act 1984, s.175A. https://www.legislation.gov.uk/ukpga/1984/51/section/175A ↩

  13. Inheritance Tax Act 1984, s.175A(3). https://www.legislation.gov.uk/ukpga/1984/51/section/175A ↩

  14. HMRC Internal Manual, IHTM28029 -- Liabilities: Non-Repayment. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm28029 ↩

  15. Inheritance Tax Act 1984, s.162B. https://www.legislation.gov.uk/ukpga/1984/51/section/162B ↩

  16. Inheritance Tax Act 1984, s.162B, as inserted by Finance Act 2013. https://www.legislation.gov.uk/ukpga/1984/51/section/162B ↩

  17. HMRC Internal Manual, IHTM10365 -- Mortgages and Secured Loans. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm10365 ↩

  18. Finance Act 2016, ss.8D-8M -- Residence Nil-Rate Band. https://www.legislation.gov.uk/ukpga/2016/24/section/8D ↩

  19. HMRC IHT435 -- Claim for Residence Nil-Rate Band. https://assets.publishing.service.gov.uk/media/67ee9503e9c76fa33048c768/claim-for-residence-nil-rate-band-iht435.pdf ↩

  20. HM Government, Inheritance Tax Thresholds and RNRB Taper. https://www.gov.uk/inheritance-tax ↩

  21. Finance Act 2016, ss.8FA-8FE -- Downsizing Provisions. https://www.legislation.gov.uk/ukpga/2016/24/section/8FA ↩

  22. HMRC IHT435 -- Claim for Residence Nil-Rate Band. https://assets.publishing.service.gov.uk/media/67ee9503e9c76fa33048c768/claim-for-residence-nil-rate-band-iht435.pdf ↩

  23. HM Government, Inheritance Tax: Unused Pension Funds and Death Benefits (October 2024, updated July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  24. HM Government, Inheritance Tax on Pensions: Liability, Reporting and Payment -- Consultation (2025). https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment ↩

  25. HM Government, Inheritance Tax: Unused Pension Funds and Death Benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  26. Equity Release Council, 2025 Annual Customer Data -- 13% of releases used for gifting. https://www.equityreleasecouncil.com/news_type/market-research-data/ ↩

  27. Finance Act 2004, Schedule 15 -- Pre-Owned Assets Tax. https://www.legislation.gov.uk/ukpga/2004/12/schedule/15 ↩

  28. FCA Handbook, MCOB 8.5A -- Equity Release Advising and Selling Standards. https://www.handbook.fca.org.uk/handbook/MCOB/8/5A.html ↩

  29. FCA Handbook, MCOB 8.6A -- Equity Release Execution-Only. https://www.handbook.fca.org.uk/handbook/MCOB/8/5A.html ↩

  30. FCA Multi-Firm Review, Equity Release Sales and Advice Process (June 2020). https://www.fca.org.uk/publications/multi-firm-reviews/equity-release-sales-and-advice-process-key-findings ↩

  31. FCA Multi-Firm Review, Action Needed to Ensure Good Outcomes for Later Life Mortgage Borrowers (September 2023). https://www.fca.org.uk/publications/multi-firm-reviews/action-needed-ensure-good-outcomes-later-life-mortgage-borrowers ↩

  32. FCA Portfolio Letter, Strategy for Lifetime Mortgage Providers (2025). https://www.fca.org.uk/publication/correspondence/portfolio-letter-fca-strategy-lifetime-mortgage-providers-2025.pdf ↩

  33. Care Act 2014, ss.14-17 -- Financial Assessment and Charging. https://www.legislation.gov.uk/ukpga/2014/23/section/17 ↩

  34. FCA Feedback Statement FS25/6, Mortgage Rule Review (December 2025). https://www.fca.org.uk/publications/feedback-statements/fs25-6-mortgage-rule-review-feedback-dp25-2-and-roadmap ↩

  35. FCA Portfolio Letter, Strategy for Lifetime Mortgage Providers (2025). https://www.fca.org.uk/publication/correspondence/portfolio-letter-fca-strategy-lifetime-mortgage-providers-2025.pdf ↩

  36. FCA Feedback Statement FS25/6, Mortgage Rule Review -- Advisor Capacity Data (December 2025). https://www.fca.org.uk/publications/feedback-statements/fs25-6-mortgage-rule-review-feedback-dp25-2-and-roadmap ↩

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