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Post-Death Tax Planning: Opportunities Your Clients (and You) Are Missing

· 19 min

Executive Summary

The two-year post-death window under sections 142-146 of the Inheritance Tax Act 1984 provides a structured statutory framework for rearranging estate devolution, yet practitioners across financial advice, tax, and estate planning consistently under-utilise these provisions. With the nil-rate band frozen at GBP 325,000 until 2030-31, the residence nil-rate band taper eroding relief for estates above GBP 2 million, and unused pension funds set to enter the inheritance tax estate from April 2027 under provisions currently progressing through Parliament, the economic value of competent post-death intervention has never been greater. This article examines the full statutory toolkit -- deeds of variation, compliance with testator wishes, discretionary trust appointments, and court order provisions -- and quantifies the savings available through worked examples. It addresses the capital gains tax and trust registration traps that accompany these mechanisms, and considers the professional negligence implications of failing to advise on post-death options.

1. The Post-Death Planning Window That Most Advisers Overlook

Estate administration is frequently treated as an administrative exercise: secure the grant of probate, collect assets, settle liabilities, distribute to beneficiaries. For many financial advisers, the engagement ends with asset transfer and, where applicable, reinvestment of inherited funds. This approach overlooks what is arguably the most significant tax planning opportunity available in the UK fiscal framework -- a statutory two-year window during which the devolution of an estate can be fundamentally restructured for inheritance tax (IHT), capital gains tax (CGT), and (indirectly) income tax purposes.1

Sections 142-146 of the Inheritance Tax Act 1984 (IHTA 1984) provide five distinct mechanisms through which beneficiaries, trustees, and courts can alter how assets pass on death, with the alteration treated for IHT purposes as if it had been effected by the deceased.2 These provisions were enacted specifically to permit post-death rearrangement. They are not loopholes; HMRC's own Inheritance Tax Manual dedicates an entire chapter to their operation, beginning at IHTM35000.1

The fiscal context of 2025-2027 makes these provisions more valuable than at any point in their forty-year history. The nil-rate band (NRB) has been frozen at GBP 325,000 since 2009, with the freeze now extended to 2030-31 following the Autumn Budget 2025.3 The residence nil-rate band (RNRB) remains at GBP 175,000, but the taper threshold of GBP 2 million has not been index-linked, meaning fiscal drag continues to strip the RNRB from estates that would have retained it just a few years ago.4 From 6 April 2025, the domicile-based IHT system has been replaced by a residence-based regime under Finance Act 2025, introducing the long-term UK resident test for worldwide asset exposure.5 And from April 2027, most unused pension funds and death benefits are set to enter the IHT estate for the first time, subject to the passage of Finance (No.2) Bill 2025-26, creating entirely new interactions between post-death planning and nil-rate band allocation.67

Against this background, the failure to consider post-death planning in every estate administration engagement represents both a missed opportunity for client families and a growing professional liability risk for advisers.

2. The Statutory Toolkit: Sections 142-146 IHTA 1984

2.1 Deeds of Variation -- Section 142

Section 142 permits any beneficiary to redirect their inheritance by written instrument within two years of death.8 The variation is treated for both IHT and CGT purposes as if the deceased had made the altered disposition in the will. For instruments executed on or after 1 August 2002, the deed must contain a statement of intent that the parties intend s142 to apply.9 Critically, no consideration in money or money's worth may pass from the new beneficiary to the original beneficiary -- though consideration provided from outside the estate does not disqualify the variation.10

Several features of s142 are frequently misunderstood. First, a variation can be executed after the estate has been fully administered and the property distributed to the original beneficiary; the two-year clock runs from the date of death, not from the grant of probate or the completion of administration.11 Second, where a beneficiary dies within the two-year period, the executor of the deceased beneficiary's estate can execute the variation on their behalf.12 Third, a valid election under s142 is irrevocable, and the same property (or any part of it) cannot be redirected a second time -- reinforcing the need for careful drafting at the outset.13

Importantly, s142 variations do not constitute gifts by the redirecting beneficiary. The variation is treated as if the deceased's will had been written differently, so no potentially exempt transfer (PET) or chargeable lifetime transfer (CLT) is created, and the seven-year survival rule does not apply to the person executing the deed.14

2.2 Compliance with Testator Wishes -- Section 143

Section 143 addresses precatory trusts and letters of wishes. Where a testator expresses a wish in the will that property should be transferred by the legatee to other persons, and the legatee complies with that wish within two years of death, the transfer is treated as if the deceased had bequeathed the property directly to the ultimate recipient.15 Unlike s142, no election or statement of intent is required. This provision is under-utilised in practice, partly because advisers may not review the will text for precatory language, and partly because s142 variations have become the default post-death planning mechanism.

2.3 Discretionary Will Trust Appointments -- Section 144

Section 144 applies where a will creates a discretionary trust and the trustees make distributions within two years of death, before any qualifying interest in possession has subsisted.16 The distribution is "read back" into the will for IHT purposes: no exit charge arises, and IHT is calculated as if the will had directed the property to the appointee from the outset. Finance Act 2006 extended s144 to cover immediate post-death interests, trusts for bereaved minors, and age 18-25 trusts.17

The interaction between s142 and s144 merits attention. HMRC guidance at IHTM35085 confirms that a s142 variation can follow a s144 event, and vice versa, provided each instrument independently satisfies its own conditions.18

The Frankland Trap. Historically, appointments within the first three months of death risked falling outside s144 relief due to the interaction with IHTA 1984, s65(4). However, for deaths on or after 10 December 2014, s65(4) no longer applies to first-quarter distributions, meaning the so-called Frankland trap has been legislatively closed for all recent deaths.19

2.4 Court Orders under the 1975 Act -- Section 146

Where a court makes an order under the Inheritance (Provision for Family and Dependants) Act 1975, s146 provides that the property is treated for IHT purposes as if it had devolved subject to the provisions of the order.20 Claims under the 1975 Act must be issued within six months of the grant of probate. Compromise settlements also benefit from s146 treatment and, per IHTM35100, are not caught by the consideration bar that would otherwise disqualify a s142 variation.21 This creates a legitimate planning angle: where a beneficiary has a bona fide 1975 Act claim, settling that claim can achieve IHT-efficient redistribution that a straightforward variation could not achieve because consideration would disqualify it.

2.5 Disclaimers

A beneficiary may also disclaim an inheritance, provided the disclaimer is made before the beneficiary has accepted any benefit from the property. Unlike a variation, a disclaimer cannot redirect the property to a specific person -- it simply causes the property to devolve as if the disclaiming beneficiary had predeceased. This limits the planning utility of disclaimers but makes them useful where the intestacy or substitution provisions in the will produce a more tax-efficient result than the original disposition.

3. Five Post-Death Planning Opportunities Advisers Are Missing

3.1 Generation-Skipping to Avoid Double Taxation

Where a parent inherits from a grandparent but is themselves elderly or terminally ill, the assets will be taxed twice: once on the grandparent's death and again on the parent's subsequent death. A s142 variation redirecting the inheritance to the grandchild (or into trust for the grandchild) eliminates the second IHT charge. On an estate of GBP 500,000 above the NRB, this saves GBP 200,000 (GBP 500,000 at 40%). Because the variation is read back into the deceased's will, the redirecting parent is not treated as making a PET.22

3.2 Spousal Redirection to Secure Spouse Exemption

Where a will leaves assets outright to adult children, the surviving spouse receives nothing and the NRB may be consumed on the first death. A s142 variation redirecting assets to the surviving spouse secures the unlimited spouse exemption on the first death, preserves the full transferable NRB for the second death, and (if the property includes the family home) may preserve the RNRB for the second death as well.23 The potential saving on an estate worth GBP 1 million, where the NRB and RNRB are fully available on the second death, could be up to GBP 200,000 (the difference between taxing GBP 500,000 at 40% on the first death versus sheltering the entire estate on both deaths through combined allowances of GBP 1 million).

3.3 Charitable Giving to Trigger the 36% Rate

Where at least 10% of the "baseline amount" of the estate passes to charity, the IHT rate reduces from 40% to 36% under IHTA 1984, Schedule 1A.24 A post-death variation can create a charitable gift where the deceased's will made no provision for charity. On a net estate of GBP 1 million, the baseline amount (after deducting the GBP 325,000 NRB) is GBP 675,000. A charitable gift of GBP 67,500 (10%) reduces the IHT rate to 36%, yielding an IHT charge of GBP 218,700 (36% of GBP 607,500) rather than GBP 270,000 (40% of GBP 675,000). The family gives away GBP 67,500 but saves GBP 51,300 in IHT -- a net cost of only GBP 16,200 for a GBP 67,500 charitable donation.

3.4 Residence Nil-Rate Band Recovery Through Section 144

Where a home is left to a discretionary will trust, no RNRB is available because there is no direct descendant "closely inheriting."25 However, if the trustees appoint the property (or a share of it) to a direct descendant within two years of death, s144 reads the appointment back into the will, making the RNRB available. The RNRB of GBP 175,000 represents a potential IHT saving of GBP 70,000 (GBP 175,000 at 40%) -- or GBP 140,000 for a married couple where both the deceased's and the transferable RNRB are recovered.26

This is particularly relevant for estates containing wills drafted before the RNRB was introduced in April 2017. Where the family home was placed in a discretionary trust for flexibility, the RNRB was inadvertently lost. A s144 appointment to a child or grandchild within two years recovers the relief without disturbing the broader estate plan.

3.5 Unwinding Outdated Nil-Rate Band Discretionary Trusts

Wills drafted before the introduction of the transferable nil-rate band on 9 October 2007 frequently contained nil-rate band discretionary trusts (NRBDTs): the testator left an amount equal to the NRB to a discretionary trust (typically for the surviving spouse and children), with the residue passing to the surviving spouse under the spouse exemption.27 These trusts served a legitimate purpose before transferability, but in the current regime they carry three significant disadvantages: (a) the surviving spouse cannot claim the transferable NRB on the second death because it was used on the first death; (b) if the trust holds the family home, the RNRB is unavailable; and (c) the trust incurs ongoing ten-yearly charges and exit charges under the relevant property regime.

A s144 appointment of the trust assets to the surviving spouse within two years of death "unwinds" the NRBDT.28 The appointment is read back into the will, the assets are treated as passing to the spouse under the spouse exemption, and the full NRB and RNRB are preserved for the second death. On a combined basis, this can preserve up to GBP 1 million in combined allowances (two NRBs of GBP 325,000 plus two RNRBs of GBP 175,000) and eliminate IHT charges of up to GBP 400,000.

4. CGT, Income Tax, and Trust Registration: The Traps

4.1 CGT Treatment -- The Section 142/Section 144 Distinction

For s142 variations, section 62(6) of the Taxation of Chargeable Gains Act 1992 provides CGT read-back: the variation is treated as if the deceased had made the disposition, and the new beneficiary acquires the asset at its probate value.29 This means a s142 variation typically triggers no CGT liability.

For s144 appointments, there is no equivalent CGT provision. HMRC's Capital Gains Manual at CG31430 confirms that where trustees exercise powers of appointment after assets have vested in them, this constitutes a disposal for CGT purposes at market value.30 However, HMRC practice treats appointments made during the administration period -- before assets have vested in the trustees -- as disposals to legatees at probate value, producing no CGT liability. The timing of the appointment relative to the completion of administration is therefore critical. Practitioners advising on s144 appointments must establish whether administration has been completed and, if so, whether any capital gain has accrued since the date of death.

This CGT/IHT asymmetry for s144 is one of the most common sources of professional error in post-death planning.

4.2 Income Tax Exclusion

Deeds of variation and s144 appointments are effective for IHT and CGT purposes but do not alter the income tax position.31 Income arising on trust assets during the administration period is taxed according to the trust's actual status (not the deemed status under s142 or s144). Where a s142 variation creates a new trust or alters the beneficial interests in existing trust income, the income tax consequences must be analysed independently of the IHT and CGT treatment.

4.3 Trust Registration Service Obligations

Trusts created by deeds of variation must be registered with HMRC's Trust Registration Service (TRS).32 HMRC's Trust Registration Service Manual at TRSM23020 clarifies that for TRS purposes, the trust is created by the deed (not by the will), the settlor is the person entering into the deed, and the trust comes into existence at the date of the deed -- even though IHT and CGT provisions treat the trust as if it had been created by the will. This creates a distinction between the trust's general law identity and its deemed identity for tax purposes. Failure to register is a compliance breach with potential penalties, and the registration obligation is frequently overlooked in the context of post-death planning.

5. The 2025-2027 Fiscal Context: Why Post-Death Planning Matters More Now

5.1 Frozen Thresholds and Fiscal Drag

The NRB has been frozen at GBP 325,000 since 2009, and the RNRB at GBP 175,000 since 2020-21, with the freeze now extended to 2030-31 following the Autumn Budget 2025.33 In real terms, the NRB has lost approximately 40% of its value since 2009. The Office for Budget Responsibility has estimated that the number of estates paying IHT will continue to rise as a consequence of fiscal drag -- meaning that more estates require active tax planning, and the value of each planning intervention increases proportionally.

The RNRB taper, which withdraws GBP 1 of RNRB for every GBP 2 of estate value above GBP 2 million, is particularly punitive for estates in the GBP 2-2.35 million range (for a single person).34 A post-death variation that reduces the net estate below the taper threshold -- for example, by redirecting assets to a surviving spouse or to charity -- can recover the full RNRB and deliver IHT savings disproportionate to the value of the redirected assets.

5.2 The Residence-Based IHT Regime

The Finance Act 2025 replaced the domicile-based IHT system with a residence-based regime from 6 April 2025.35 An individual is now a long-term UK resident (and within full IHT scope on worldwide assets) where they have been resident in the UK for at least 10 out of the last 20 tax years. Tail provisions of 3-10 years apply after departure, depending on the length of prior UK residence.36

For post-death planning purposes, the new regime introduces complexity where the deceased held non-UK assets. Where the deceased was a long-term UK resident, worldwide assets are within the IHT estate and post-death variations affecting overseas assets operate in the same way as for UK assets. Where the deceased was not a long-term UK resident, excluded property rules may apply to non-UK assets, and variations redirecting such assets require careful analysis of whether the excluded property status survives the variation. Transitional rules apply for individuals who were not UK-domiciled on 30 October 2024 and have not been UK-resident since 2025-26.37

5.3 Pension Death Benefits from April 2027

The Finance (No.2) Bill 2025-26, currently progressing through Parliament, contains provisions to bring most unused pension funds and death benefits within the IHT estate from 6 April 2027.38 The Bill completed Committee of the Whole House on 13 January 2026 and was in Public Bill Committee as of the date of this article; it is expected to receive Royal Assent during 2026, but as of 4 February 2026 it remains a Bill rather than an Act, and practitioners should monitor its parliamentary progress.7 Under these provisions, personal representatives (not pension scheme administrators) will be liable for reporting and paying IHT on pension assets.39 This change would fundamentally alter the post-death planning calculus. Where pension assets form part of the estate, the NRB must be shared proportionally between pension and non-pension assets. Post-death restructuring of non-pension assets through s142 variations -- redirecting assets to a surviving spouse (exempt) or to charity (exempt) -- can free up NRB capacity to shelter pension assets from the 40% charge.

The interaction between income tax (which will apply to pension death benefits received by beneficiaries) and IHT (which will apply to the pension fund within the estate) creates a potential double taxation risk that makes the overall allocation of reliefs between pension and non-pension assets a critical planning consideration.

5.4 Agricultural and Business Property Relief Cap

The October 2024 Budget announced a cap on 100% agricultural property relief (APR) and business property relief (BPR) from April 2026. On 23 December 2025, the government confirmed the combined allowance for 100% relief at GBP 2.5 million per individual (increased from the originally proposed GBP 1 million), with qualifying property above the cap attracting relief at 50% (an effective IHT rate of 20%).40 For estates containing agricultural or business property above this cap, post-death variations can be used to restructure the allocation of assets between beneficiaries to maximise the available relief. For example, directing business property to a beneficiary who will retain it (preserving BPR conditions) while redirecting non-qualifying assets to secure spouse exemption may optimise the overall tax position.

6. Professional Obligations and Negligence Risk

The duty to advise on post-death planning options is not merely a matter of best practice; it carries professional liability implications. Where an adviser is retained to assist with estate administration -- whether for probate, investment management, pension consolidation, or tax reporting -- the scope of the retainer may extend to identifying tax-efficient opportunities. Failure to advise beneficiaries of the existence of the two-year post-death planning window, particularly where the potential IHT saving is substantial, creates exposure to professional negligence claims.

Financial advisers are particularly well-positioned to identify post-death opportunities because of their comprehensive view of the deceased's financial position. Unlike solicitors (who may see only the will and estate assets) or accountants (who may see only tax returns), IFAs typically have visibility across investments, pensions, insurance policies, and -- critically -- the beneficiaries' existing financial positions. This cross-asset visibility is essential for determining whether a variation, disclaimer, or trust appointment would produce a net benefit after accounting for IHT, CGT, and income tax consequences across all affected parties.

Practitioners should consider implementing a post-death planning review as a standard component of every estate administration engagement, with a documented assessment of whether any of the ss142-146 mechanisms could benefit the estate. This documented assessment serves both as a quality-of-service differentiator and as evidence of proper advice in the event of a subsequent negligence claim.

Conclusion

The statutory toolkit under IHTA 1984 ss142-146 represents a carefully constructed framework for post-death estate rearrangement -- one that Parliament enacted precisely because the devolution of property on death does not always reflect the most tax-efficient outcome. The provisions are not aggressive; they are built into the architecture of the inheritance tax system, supported by extensive HMRC guidance, and available in every estate where the two-year window has not expired.

The current fiscal environment -- frozen nil-rate bands extended to 2030-31, a residence nil-rate band being eroded by taper and fiscal drag, a new residence-based IHT regime, and the proposed inclusion of pension death benefits -- makes post-death planning more valuable than at any point since these provisions were enacted. For financial advisers and tax professionals, the question is not whether post-death planning is relevant to their practice; it is whether their current estate administration workflow ensures that no two-year window closes without a systematic review of the available options.

Integrating post-death planning review into standard estate administration protocols requires modest additional effort but can deliver substantial client outcomes, differentiate advisory practices, and mitigate the professional negligence risk that accompanies inaction.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Estate Planning, Inheritance Tax, Trust Administration, Financial Advice

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the four statutory provisions (ss142, 143, 144, 146 IHTA 1984) that permit post-death alteration of estate devolution for IHT purposes, and distinguish their respective conditions and limitations.
  2. Distinguish between the IHT, CGT, and income tax treatment of deeds of variation under s142 and discretionary will trust appointments under s144, including the CGT read-back asymmetry.
  3. Evaluate when a s144 appointment from a discretionary will trust should be used to recover the residence nil-rate band or unwind an outdated nil-rate band discretionary trust.
  4. Calculate the IHT saving from a post-death variation redirecting assets to a surviving spouse, to charity (triggering the 36% rate under IHTA 1984, Schedule 1A), or to the next generation.
  5. Assess the professional negligence risk arising from failure to advise beneficiaries of post-death planning options within the two-year statutory window.

CII Competency Mapping

  • R06: Financial Planning Practice -- Estate planning and IHT mitigation strategies
  • CF8: Long-term Care Insurance -- Integration of estate planning with later-life financial planning
  • AF1: Personal Tax and Trust Planning -- Trust taxation, CGT on death, post-death restructuring

Reflective Questions

  1. How does the current estate administration workflow within the practice ensure that every client estate is assessed for post-death planning opportunities before the two-year window expires?
  2. What additional training or professional development would paraplanners and support staff require to identify potential s142 or s144 opportunities during the estate administration process?
  3. How might the inclusion of pension death benefits in the IHT estate from April 2027 change the advice process for clients with significant undrawn pension funds?

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. HMRC Inheritance Tax Manual, IHTM35000 -- Alterations to the Devolution of an Estate (Contents). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35000 ↩ ↩2

  2. Inheritance Tax Act 1984, ss142-146. https://www.legislation.gov.uk/ukpga/1984/51/section/142 ↩

  3. GOV.UK, Inheritance Tax Thresholds (including Autumn Budget 2025 extension to 2030-31). https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  4. GOV.UK, Inheritance Tax Residence Nil Rate Band Guidance. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩

  5. Finance Act 2025, Schedule 13 -- Inheritance Tax: Long-term UK Residents. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩

  6. GOV.UK, Inheritance Tax: Unused Pension Funds and Death Benefits -- Policy Paper. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  7. Finance (No.2) Bill 2025-26, UK Parliament. https://bills.parliament.uk/bills/4042 ↩ ↩2

  8. Inheritance Tax Act 1984, s142(1). https://www.legislation.gov.uk/ukpga/1984/51/section/142 ↩

  9. HMRC Inheritance Tax Manual, IHTM35011 -- Instruments of Variation. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35011 ↩

  10. HMRC Inheritance Tax Manual, IHTM35100 -- Consideration. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35100 ↩

  11. HMRC Inheritance Tax Manual, IHTM35032. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35032 ↩

  12. HMRC Inheritance Tax Manual, IHTM35042 -- Variations by Executors of Deceased Beneficiaries. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35042 ↩

  13. HMRC Inheritance Tax Manual, IHTM35081. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35081 ↩

  14. HMRC Inheritance Tax Manual, IHTM35151. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35151 ↩

  15. Inheritance Tax Act 1984, s143. https://www.legislation.gov.uk/ukpga/1984/51/section/143 ↩

  16. Inheritance Tax Act 1984, s144. https://www.legislation.gov.uk/ukpga/1984/51/section/144 ↩

  17. HMRC Inheritance Tax Manual, IHTM35182 -- When Does s144 Apply. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35182 ↩

  18. HMRC Inheritance Tax Manual, IHTM35085 -- Interaction Between s142 and s144. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35085 ↩

  19. HMRC Inheritance Tax Manual, IHTM42227 -- Variation of Discretionary Will Trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm42227 ↩

  20. Inheritance Tax Act 1984, s146; Inheritance (Provision for Family and Dependants) Act 1975. https://www.legislation.gov.uk/ukpga/1984/51/section/146 ↩

  21. HMRC Inheritance Tax Manual, IHTM35100. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35100 ↩

  22. Inheritance Tax Act 1984, s142; HMRC Inheritance Tax Manual, IHTM35151. https://www.legislation.gov.uk/ukpga/1984/51/section/142 ↩

  23. GOV.UK, Inheritance Tax: Transfer of Threshold. https://www.gov.uk/guidance/inheritance-tax-transfer-of-threshold ↩

  24. Inheritance Tax Act 1984, Schedule 1A -- Reduced Rate of Tax Where Estate Includes Charitable Gift. https://www.legislation.gov.uk/ukpga/1984/51/schedule/1A ↩

  25. GOV.UK, Check if You Can Get an Additional Inheritance Tax Threshold. https://www.gov.uk/guidance/check-if-you-can-get-an-additional-inheritance-tax-threshold ↩

  26. GOV.UK, Inheritance Tax Residence Nil Rate Band Guidance. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩

  27. GOV.UK, Inheritance Tax: Transfer of Threshold. https://www.gov.uk/guidance/inheritance-tax-transfer-of-threshold ↩

  28. HMRC Inheritance Tax Manual, IHTM35182; IHTM42227. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35182 ↩

  29. Taxation of Chargeable Gains Act 1992, s62(6); HMRC Capital Gains Manual, CG31630. https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg31630 ↩

  30. HMRC Capital Gains Manual, CG31430. https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg31430 ↩

  31. HMRC Trusts, Settlements and Estates Manual, TSEM1815. https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem1815 ↩

  32. HMRC Trust Registration Service Manual, TRSM23020. https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm23020 ↩

  33. GOV.UK, Inheritance Tax Thresholds (including Autumn Budget 2025 extension to 2030-31). https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  34. GOV.UK, Inheritance Tax Residence Nil Rate Band Guidance. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩

  35. Finance Act 2025, ss44-46 and Schedule 13. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩

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

  37. GOV.UK, Changes to the Taxation of Non-UK Domiciled Individuals. https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals ↩

  38. GOV.UK, 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 ↩

  39. GOV.UK, Inheritance Tax on Pensions: Consultation Outcome. 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 ↩

  40. GOV.UK, Agricultural Property Relief and Business Property Relief Changes (including 23 December 2025 increase to GBP 2.5 million). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

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