Skip to main content
WUHLD
← Back to insights

Investment Bond Estate Planning: Tax Efficiency and Trust Structures

· 19 min

Executive Summary

Investment bonds held in trust occupy a distinctive position in estate planning, combining income tax deferral under the chargeable event regime (ITTOIA 2005, Part 4, Chapter 9) with inheritance tax reduction through established trust structures. With IHT receipts reaching GBP 6.6 billion in the first nine months of 2025-26, the nil-rate band frozen at GBP 325,000 through 2030-31, and pension death benefits entering the taxable estate from April 2027, demand for structured bond-trust solutions is intensifying. The settlor-as-chargeable-person rule under ITTOIA 2005, s.465 remains the single most consequential planning variable: top-slicing relief is available during the settlor's lifetime but lost entirely when trustees become liable at 45% after death. This article provides IFAs and investment specialists with a comparative framework for deploying discounted gift trusts, loan trusts, and gift trusts under the reformed IHT regime, alongside practical guidance on segment management and excess event mitigation.

1. The Renewed Case for Bond-Trust Estate Planning

The strategic rationale for investment bonds within trust structures has strengthened materially since April 2025. Three concurrent fiscal developments create a compounding effect on estates that previously fell below the IHT threshold or relied on alternative planning vehicles.

Frozen Thresholds and Fiscal Drag

The IHT nil-rate band has remained at GBP 325,000 since 2009-10, with the residence nil-rate band fixed at GBP 175,000 since 2020-21.1 Both thresholds are now frozen through 2030-31 following Budget 2025.2 The cumulative effect of seventeen years of threshold stasis against asset price inflation is reflected in IHT receipts: HMRC reported GBP 6.6 billion in IHT receipts for April to December 2025, GBP 232 million higher than the same period in the prior year.3 The OBR forecasts total IHT receipts of GBP 9.1 billion for 2025-26, rising to GBP 14.5 billion by 2030-31.4 Fiscal drag is drawing an increasing number of estates into the IHT net, expanding the client population for whom structured estate planning is relevant and timely.

Pension Death Benefits and the April 2027 Watershed

From 6 April 2027, unused pension funds and death benefits will be included in the deceased's estate for IHT purposes.5 HMRC estimates 10,500 estates will acquire a new IHT liability, with an average additional charge of GBP 34,000.6 The personal representative-led reporting model has been confirmed following consultation. This change removes the pension fund's historical role as an IHT-free death benefit vehicle. Clients who previously relied on pension wealth falling outside the estate will require alternative planning structures. Investment bonds in trust -- which can achieve partial or full estate reduction while offering features unavailable from pension wrappers, such as the 5% cumulative withdrawal facility and segment assignment -- represent a direct structural response to this legislative shift.

The Residence-Based IHT Regime

The residence-based IHT regime, enacted through Finance Act 2025 and operational from 6 April 2025, replaced domicile with a long-term UK resident (LTUR) test.7 An individual becomes a long-term UK resident for IHT purposes after being UK-resident for at least 10 of the preceding 20 tax years. Departing residents face tail provisions of 3 to 10 years depending on the length of UK residence.8 For excluded property trusts under IHTA 1984, s.48, the settlor's LTUR status at the date the settlement was made -- rather than their domicile -- now determines whether non-UK situated assets are excluded property.9 This fundamentally alters the planning landscape for offshore bonds in trust, a point examined in Section 6.

Why Investment Bonds Are Suited to Trust-Based Estate Planning

Investment bonds -- single-premium life assurance contracts used as investment wrappers -- generate no annual income tax or capital gains tax liability during the accumulation phase.10 Growth within the bond is subject only to the chargeable event regime, with tax deferred until a qualifying event occurs. This characteristic makes bonds uniquely compatible with trust-based estate planning, where the investment horizon may span decades and the absence of annual tax reporting obligations simplifies trust administration. The bond's segmented structure (typically 20 to 100 identical policies) enables partial encashment through segment surrender rather than part withdrawal, offering materially different tax outcomes as examined in Section 5. No equivalent segment flexibility is available from open-ended investment companies, unit trusts, or direct equity holdings.

2. The Chargeable Event Regime: How Investment Bonds Are Taxed

The taxation of investment bonds is governed by ITTOIA 2005, Part 4, Chapter 9.11 Unlike collective investment schemes taxed under CGT and income tax rules, bonds operate under a self-contained regime in which tax arises only on the occurrence of a chargeable event that produces a gain.

Chargeable Events and Gain Calculation

Chargeable events include: death of the life assured, maturity, full surrender, assignment for money or money's worth, and excess events arising from part surrenders exceeding the cumulative 5% allowance.12 The gain is calculated as the difference between the amount received (or the surrender value at death) and the aggregate of premiums paid, less any gains previously charged. Chargeable event gains are classified as savings income for income tax purposes, which has implications for interaction with the personal savings allowance and the starting rate for savings.

The 5% Cumulative Withdrawal Allowance

The policyholder may withdraw up to 5% of the original premium per annum without triggering a chargeable event gain.13 Unused allowance carries forward cumulatively: a bond held for eight years without withdrawals accumulates a 40% allowance. Withdrawals exceeding the cumulative allowance trigger an excess event under ITTOIA 2005, s.509, with the gain calculated as the excess of total withdrawals over the cumulative 5% threshold.14 This gain may bear no relationship to actual investment performance -- a critical risk factor examined in Section 5.

Onshore Versus Offshore Bonds

Onshore bonds are held within UK life companies subject to corporation tax on internal fund returns. HMRC treats this internal taxation as equivalent to basic rate income tax having been paid, providing a 20% basic rate credit against any chargeable event gain.15 Basic rate taxpayers face no further liability. Higher rate taxpayers pay an effective 20% on gains from onshore bonds; additional rate taxpayers pay 25%.

Offshore bonds benefit from gross roll-up: no UK income tax or CGT is deducted within the fund, subject to irrecoverable withholding taxes in the bond's jurisdiction.16 The full chargeable event gain is taxable at the individual's marginal rate with no basic rate credit. Offshore bonds may prove more efficient where the investor anticipates being a basic rate or non-taxpayer at the point of encashment. The distinction between onshore and offshore becomes particularly significant for bonds held in trust, where the effective trustee rate diverges materially: 25% for onshore bonds (45% less the 20% credit) versus the full 45% for offshore bonds.

Top-Slicing Relief

Top-slicing relief under ITTOIA 2005, ss.535-536 divides the chargeable event gain by the number of complete years the bond has been held, calculating the tax on the annual equivalent and then grossing up to determine the total liability.17 This mechanism can reduce the effective rate of tax significantly where a large gain accumulated over many years would otherwise push the policyholder into a higher marginal band. Critically, top-slicing relief is available to individuals -- including settlors assessed under s.465 -- but is not available to trustees or personal representatives.18

3. Bonds in Trust: The Person Liable for Tax

The identity of the chargeable person for bonds held in trust is the single most consequential planning variable in this area. The rules, codified in ITTOIA 2005, ss.465-467, create fundamentally different tax outcomes depending on whether the settlor is alive at the date of the chargeable event.

Settlor Liability During Lifetime

Where a UK-resident individual created the trust, the settlor is the chargeable person for any chargeable event gain arising during their lifetime under ITTOIA 2005, s.465.19 The gain forms part of the settlor's total income and is subject to their marginal rate of tax. Top-slicing relief is available, potentially reducing the effective rate substantially below the headline marginal rate. The settlor's personal savings allowance (GBP 500 for higher rate taxpayers) may also apply to chargeable event gains classified as savings income.

Trustee Liability After the Settlor's Death

After the settlor's death, trustees become the chargeable person under ITTOIA 2005, s.467.20 The gain is assessed at the trust rate of 45%. For onshore bonds, the 20% basic rate credit reduces the effective rate to 25%. However, the trust standard rate band (GBP 1,000, divided where the settlor has created multiple trusts) is taxed at only 20%, providing minimal relief on larger gains. Top-slicing relief is not available to trustees.21

Quantified Comparison

Consider a GBP 500,000 onshore bond generating a GBP 100,000 chargeable event gain after 10 years. If the settlor (a higher rate taxpayer with total income of GBP 60,000 before the gain) is assessed under s.465, top-slicing divides the gain by 10, producing an annual equivalent of GBP 10,000. The settlor's liability on the full gain, after the basic rate credit, could be as low as GBP 10,000 to GBP 12,000 depending on the interaction with personal allowance tapering. If trustees are assessed at 45% after the settlor's death, the liability on the same gain is GBP 25,000 (the effective 25% after the basic rate credit on the amount exceeding the GBP 1,000 standard rate band). The differential of GBP 13,000 to GBP 15,000 on a single GBP 100,000 gain underscores the planning imperative to manage chargeable events during the settlor's lifetime.

The Segment Assignment Strategy

Assignment of bond segments by way of gift does not itself trigger a chargeable event.22 Subsequent gains on assigned segments are assessed on the assignee (the beneficiary) at their marginal rate, with top-slicing relief available. Trustees of discretionary trusts can assign segments to beneficiaries who are basic rate or non-taxpayers before encashment, reducing the effective tax rate from 25% (trustee rate on onshore bonds) to nil or a marginal amount. An IHT exit charge under IHTA 1984, s.65 may apply on the capital leaving the trust, but this is calculated on the trust fund value, not the chargeable event gain, and is frequently modest where the fund is below the NRB.23 This segment assignment approach represents one of the most tax-efficient distribution mechanisms available within the trust framework.

4. Trust Structures for Investment Bonds: A Comparative Framework

Three principal trust structures accommodate investment bonds for estate planning purposes. Each offers a distinct combination of IHT treatment, capital access, and income tax position.

Discounted Gift Trusts

In a discounted gift trust (DGT), the settlor transfers a single-premium bond into trust while retaining the right to predetermined regular withdrawals, typically structured to utilise the 5% allowance.24 The retained withdrawal rights have an actuarial open market value determined under IHTA 1984, s.160, using factors including the settlor's age, gender, health, and the withdrawal pattern.25 The transfer of value for IHT purposes is the premium paid minus this "discount." HMRC's valuation methodology, set out at IHTM20656, applies a Jellicoe-type formula with the open market value set at 97% of present value to reflect notional purchaser costs.26

Post-Finance Act 2006, transfers into discretionary DGTs constitute chargeable lifetime transfers (CLTs). If the discounted value exceeds the available NRB, a lifetime IHT rate of 20% applies to the excess. Gifts with reservation provisions do not apply to the retained withdrawal rights because those rights are indefeasible under the trust terms.27 The retained rights diminish over time as withdrawals are taken, progressively reducing the element within the settlor's estate. Advisors should note that the discount is typically higher for older or less healthy settlors, as the actuarial value of their retained withdrawal rights is lower.

Loan Trusts

In a loan trust arrangement, the settlor lends money interest-free and repayable on demand to the trustees, who invest the loan in a single-premium bond.28 No transfer of value occurs at inception: the loan is a debt, not a gift. The outstanding loan remains in the settlor's estate; only future investment growth falls outside. Loan repayments to the settlor are sourced from the 5% withdrawal facility or segment surrenders. As each repayment reduces both the outstanding loan (an estate asset) and the bond value (within the trust), the net IHT saving is limited to the accumulated growth.

The loan trust is suited to clients who require capital access but wish to shelter investment growth from IHT. The absence of an upfront transfer of value means no CLT entry charge and no requirement to survive seven years for the transfer to fall out of the cumulative total.

Gift Trusts

An outright gift trust involves the settlor making an irrevocable transfer of the bond into trust with no retained rights.29 The full premium constitutes a CLT (discretionary trust) or a potentially exempt transfer (absolute/bare trust). No capital access is retained. This structure achieves maximum IHT efficiency: if the settlor survives seven years from the date of a PET, or the CLT falls within the available NRB, the full value is removed from the estate.

Comparative Decision Framework

Criterion Discounted Gift Trust Loan Trust Gift Trust
IHT entry treatment CLT on discounted value No transfer of value CLT (discretionary) or PET (absolute)
Capital access retained Predetermined withdrawals Full loan repayable on demand None
Immediate IHT reduction Yes (the discount) No (loan in estate) Yes (full premium if PET/within NRB)
Growth outside estate Yes Yes Yes
Income tax on chargeable events Settlor during lifetime; trustees after death Settlor during lifetime; trustees after death Settlor during lifetime; trustees after death
Periodic/exit charges Yes (relevant property regime) Yes (relevant property regime) Yes if discretionary; no if absolute
Suited to Clients needing income access with IHT reduction; older/less healthy settlors benefit from higher discount Clients needing capital access; growth shelter without upfront IHT charge Clients with no access needs; maximum IHT efficiency required

The choice of structure is determined by the intersection of four client-specific variables: access requirements (income, capital, or none), health and age (affecting the DGT discount), estate size relative to the NRB, and the settlor's marginal income tax rate.30

5. Managing the 5% Allowance and Excess Event Risk

The 5% cumulative withdrawal facility is both a core planning tool and a source of material tax risk when mismanaged. Within DGTs, the settlor's retained withdrawals are funded from this allowance. Within loan trusts, loan repayments draw on the same facility. Advisors must monitor cumulative withdrawals against the cumulative 5% threshold across the bond's entire history.

The Excess Event Trap

When cumulative withdrawals exceed the cumulative 5% allowance, an excess chargeable event gain arises under ITTOIA 2005, s.509.31 The gain equals the excess of total withdrawals over the cumulative allowance -- not the excess over the bond's economic gain. A bond that has fallen in value can still produce a chargeable excess event gain if withdrawals exceed the cumulative threshold. This artificial gain is assessed on the settlor (during lifetime) or trustees (after death) in the policy year it arises, potentially creating an unexpected tax liability disproportionate to any economic benefit received.

Segment Surrender as the Preferred Alternative

Modern investment bonds are structured as clusters of identical policies, typically 20 to 100 segments.32 Fully surrendering individual segments triggers a chargeable event only on the gain attributable to those specific segments. The gain is calculated on a segment-by-segment basis: the surrender value of the segments minus the premiums allocated to them, less any previously taxed gains on those segments.

Consider a GBP 200,000 bond structured as 20 segments, held for six years with no prior withdrawals (cumulative 5% allowance: GBP 60,000). The client requires GBP 60,000. Under a part withdrawal strategy across all segments, the full GBP 60,000 is within the cumulative allowance and no chargeable event arises. However, if GBP 30,000 was withdrawn in year three, the remaining cumulative allowance is GBP 30,000. A further part withdrawal of GBP 60,000 produces an excess event gain of GBP 30,000, taxable regardless of whether the bond has grown. Under a segment surrender strategy, surrendering six segments (each originally GBP 10,000) with a current value of GBP 12,000 each generates a chargeable gain of GBP 2,000 per segment (GBP 12,000 total), assessed on the actual economic gain rather than an artificial excess calculation.33 The segment surrender approach generates GBP 12,000 of chargeable gain versus GBP 30,000 under the part withdrawal route -- a GBP 18,000 reduction in assessable gain.

Record-Keeping Requirements

Advisors must maintain contemporaneous records of all withdrawals and segment surrenders, reconciling cumulative withdrawals against the 5% allowance at least annually. Provider systems vary in how they report cumulative positions, and discrepancies between advisor and provider records create a risk of unexpected excess events. Consumer Duty obligations under PRIN 2A further reinforce the need for robust monitoring, as an avoidable excess event gain represents a clear failure to deliver good outcomes for the client.34

6. The Residence-Based Regime and Offshore Bond Planning

The replacement of domicile with the LTUR test from 6 April 2025 has particular significance for offshore bonds held in trust by internationally mobile clients.

Excluded Property Trust Status

Under IHTA 1984, s.48, non-UK situated property held in a settlement is excluded property -- and therefore outside the scope of IHT -- where the settlor was not domiciled in the UK at the time the settlement was made.35 From 6 April 2025, the relevant criterion is whether the settlor was a long-term UK resident at the date of settlement. An offshore bond within a trust created by a non-LTUR settlor qualifies as excluded property, sheltering it from IHT entry charges, periodic charges, and exit charges.

Planning Considerations and Tail Provisions

The LTUR test operates on a rolling basis: an individual who has been UK-resident for 10 of the preceding 20 tax years acquires LTUR status. A non-UK domiciled individual who arrived in the UK 10 years ago and has been continuously resident would become an LTUR from the start of their eleventh year of UK residence.36 Trusts created before LTUR status is acquired can benefit from excluded property status for offshore bond holdings. However, the 3-to-10-year tail provisions mean that a departing LTUR remains within the IHT net for a period after leaving the UK, depending on the duration of their prior UK residence.37 Advisors working with internationally mobile clients must therefore map both the LTUR acquisition timeline and the tail provision duration when structuring offshore bond trusts.

Income Tax Implications of Offshore Bonds in Trust

The income tax treatment of offshore bonds adds a further dimension. Where the settlor is non-UK resident at the time of a chargeable event, liability shifts to the trustees under ITTOIA 2005, s.467, who are assessed at 45% with no basic rate credit for offshore bonds -- producing the full 45% effective rate.38 Time apportionment relief under ITTOIA 2005, s.528 may reduce the gain proportionately for periods of the settlor's non-UK residence, but this relief applies to the individual, not to trustees. The interaction between LTUR status for IHT purposes and UK residence for income tax purposes requires careful coordination: a client may be non-LTUR (favourable for IHT) while UK-resident (unfavourable for offshore bond income tax on chargeable events).

Conclusion

Investment bonds held in trust remain one of the most technically nuanced intersections of income tax and IHT planning available to advisors. The convergence of frozen thresholds, pension death benefit inclusion from April 2027, and the residence-based regime from April 2025 strengthens the case for structured bond-trust solutions, but only where advisors command the underlying mechanics. The settlor-as-chargeable-person rule creates a material tax differential between lifetime and post-death chargeable events, making proactive management through segment assignment a core advisory responsibility. The choice between discounted gift trusts, loan trusts, and gift trusts must be mapped to each client's access requirements, health profile, estate composition, and marginal tax position. Consumer Duty obligations under PRIN 2A reinforce the requirement for documented suitability assessment, ensuring that bond-trust structures deliver fair value relative to alternative vehicles.39 Advisors who integrate these technical disciplines -- chargeable event management, trust structure selection, and reformed IHT rules -- are positioned to deliver demonstrable planning value in an environment of sustained fiscal pressure on estates.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Estate Planning, Investment Bond Taxation, Trust Structures, IHT Mitigation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Distinguish between the income tax treatment of chargeable event gains assessed on the settlor under ITTOIA 2005, s.465 and on trustees under s.467, including the availability of top-slicing relief
  2. Evaluate the suitability of discounted gift trusts, loan trusts, and gift trusts for investment bond estate planning based on client-specific access needs, health profile, and estate composition
  3. Calculate the tax differential between segment surrender and part withdrawal strategies when cumulative withdrawals approach the 5% allowance threshold
  4. Analyse the impact of the residence-based IHT regime on excluded property trust status for offshore bonds, applying the long-term UK resident test to settlement date determinations

FCA Competency Mapping

  • Investment products and their taxation (investment bonds, chargeable event regime)
  • Tax planning and estate planning strategies (IHT trust structures, CLTs, PETs)
  • Regulatory compliance and Consumer Duty obligations (PRIN 2A suitability, fair value assessment)

Reflective Questions

  1. How would you assess whether a discounted gift trust or loan trust better serves a client aged 72 with an estate of GBP 1.2 million and a requirement for GBP 15,000 annual income?
  2. What steps would you implement to monitor cumulative 5% withdrawal positions across multiple bond-trust arrangements within your client base?
  3. How might the April 2027 pension death benefit inclusion change the sequencing of estate planning recommendations for clients with significant defined contribution pension wealth?

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. GOV.UK -- Inheritance Tax Thresholds (updated 2025). https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  2. OBR -- Inheritance Tax Forecast (2025). https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  3. HMRC Tax Receipts and National Insurance Contributions Monthly Bulletin (January 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩

  4. OBR -- Inheritance Tax Forecast (2025). https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  5. GOV.UK -- Inheritance Tax: Unused Pension Funds and Death Benefits (2024). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  6. GOV.UK -- Inheritance Tax on Pensions: Consultation Outcome (2025). https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩

  7. Finance Act 2025, Part 2, Chapter 4 -- Inheritance Tax (Replacement of Domicile Rules). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩

  8. HMRC IHTM47020 -- Long-Term UK Residence Test. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  9. IHTA 1984, s.48 -- Excluded Property. https://www.legislation.gov.uk/ukpga/1984/51/section/48 ↩

  10. ITTOIA 2005, Part 4, Chapter 9 -- Chargeable Event Regime. https://www.legislation.gov.uk/ukpga/2005/5/part/4/chapter/9 ↩

  11. IPTM3100 -- Charge to Tax on Chargeable Events. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3100 ↩

  12. IPTM3000 -- Chargeable Events Contents. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3000 ↩

  13. IPTM1510 -- Part Surrenders and Part Assignments. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm1510 ↩

  14. IPTM3540 -- Periodic Calculations and Excess Events. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3540 ↩

  15. IPTM3810 -- Income Tax Treated as Paid. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3810 ↩

  16. IPTM3810 -- Income Tax Treated as Paid (Onshore vs Offshore Comparison). https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3810 ↩

  17. IPTM3820 -- Top-Slicing Relief General. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3820 ↩

  18. IPTM3240 -- Person Liable, Death Cases. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3240 ↩

  19. ITTOIA 2005, s.465 -- Person Liable: Settlor. https://www.legislation.gov.uk/ukpga/2005/5/section/465 ↩

  20. ITTOIA 2005, s.467 -- Person Liable: Trustees. https://www.legislation.gov.uk/ukpga/2005/5/section/467 ↩

  21. IPTM3250 -- Person Liable, Trusts Summary. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3250 ↩

  22. IPTM3250 -- Person Liable, Trusts Summary (Assignment). https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3250 ↩

  23. IHTA 1984, s.65 -- Charge at Other Times (Exit Charges). https://www.legislation.gov.uk/ukpga/1984/51/section/65 ↩

  24. IHTM20421 -- Discounted Gift Schemes Introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm20421 ↩

  25. IHTA 1984, s.160 -- Market Value. https://www.legislation.gov.uk/ukpga/1984/51/section/160 ↩

  26. IHTM20656 -- HMRC Valuation Basis for Discounted Gift Trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm20656 ↩

  27. IHTM44112 -- Pre-Owned Assets: Discounted Gift Trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm44112 ↩

  28. IHTM20501 -- Gift and Loan Trusts Introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm20501 ↩

  29. GOV.UK -- Trusts and Inheritance Tax. https://www.gov.uk/guidance/trusts-and-inheritance-tax ↩

  30. FCA -- Consumer Duty. https://www.fca.org.uk/firms/consumer-duty ↩

  31. ITTOIA 2005, s.509 -- Excess Events. https://www.legislation.gov.uk/ukpga/2005/5/part/4/chapter/9/crossheading/when-chargeable-events-occur-general ↩

  32. IPTM7330 -- Cluster Policies. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm7330 ↩

  33. IPTM3510 -- Death, Maturity, Full Surrender. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3510 ↩

  34. FCA -- Consumer Duty Focus Areas. https://www.fca.org.uk/publications/corporate-documents/consumer-duty-focus-areas ↩

  35. IHTA 1984, s.48 -- Excluded Property. https://www.legislation.gov.uk/ukpga/1984/51/section/48 ↩

  36. GOV.UK -- Inheritance Tax if You Are a Long-Term UK Resident. https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩

  37. HMRC IHTM47020 -- Long-Term UK Residence Test (Tail Provisions). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  38. ITTOIA 2005, s.467 -- Person Liable: Trustees. https://www.legislation.gov.uk/ukpga/2005/5/section/467 ↩

  39. FCA -- Consumer Duty Focus Areas. https://www.fca.org.uk/publications/corporate-documents/consumer-duty-focus-areas ↩

Preview Free