Annuity Death Benefits and Estate Planning: What Advisors Need to Know

Executive Summary

The April 2027 inheritance tax reforms represent a fundamental shift in pension death benefit taxation: most unused pension funds will enter estate valuations for the first time, affecting retirement income strategies nationwide. Yet within this landscape, joint life annuities emerge as a strategically advantaged structure, explicitly excluded from the new IHT scope. Financial Conduct Authority data confirms annuity sales reached 88,430 in 2024/25, with rates at 7.62% for single life products as of February 2026. Advisors face a critical 14-month window to review client arrangements before April 2027 implementation. This article examines the four principal death benefit structures, their divergent income tax and IHT treatments, and the practical implications for client advisory conversations. The distinction between discretionary and non-discretionary provisions proves critical to IHT planning outcomes.

1. Introduction: The Annuity Death Benefit Landscape

Annuities have long occupied an uneasy position in retirement income planning. The pension freedoms introduced in April 2015 triggered a precipitous decline in annuity purchases, as drawdown flexibility captured adviser and client attention alike. Yet recent market conditions have prompted a measured reassessment. FCA retirement income data reveals annuity sales increased 7.8% to 88,430 in 2024/25, even as drawdown sales surged 25.5% to 349,992.¹ The revival reflects competitive rates — 7.62% for a 65-year-old single life annuity as of February 2026 — combined with growing client appetite for guaranteed income in volatile markets.²

The estate planning dimension of annuities remains underexplored in advisory practice. The April 2027 IHT changes compel a fundamental reassessment: most unused pension funds and death benefits will become subject to inheritance tax, ending decades of favourable treatment for discretionary pension arrangements.³ This reform does not, however, affect all annuity structures equally. Joint life annuities are explicitly excluded from the new IHT scope, creating a distinctive planning opportunity that advisors must understand.⁴

The regulatory environment adds further complexity. The FCA's March 2024 thematic review (TR24/1) identified significant disclosure failings across retirement income advice files, with particular concerns regarding death benefit explanations and ongoing review processes.⁵ Consumer Duty requirements demand that advisors demonstrate fair value assessments and comprehensive consideration of client circumstances, including beneficiary needs and tax implications.⁶

For advisors serving clients with existing annuities or approaching retirement, the 14-month window before April 2027 presents both urgency and opportunity. Those who master the technical distinctions between death benefit structures can position annuities not as legacy products but as strategic estate planning tools when appropriately structured.

2. Death Benefit Options: Technical Framework

2.1 Joint Life Annuities: The IHT-Advantaged Structure

Joint life annuities provide continuing income to a nominated beneficiary — typically a spouse or civil partner — upon the member's death. The successor receives a predetermined proportion of the original income, commonly 50%, two-thirds, or 100% of the member's payment level. These arrangements may specify whether successor payments begin immediately upon death or after any guaranteed period concludes ("overlap" provisions).⁷

The critical estate planning advantage lies in explicit exclusion from the April 2027 IHT reforms. Government consultation outcomes confirmed that joint life annuities will not fall within the value of an individual's estate for IHT purposes after April 2027.⁴ This exemption reflects the fundamental nature of joint life arrangements: no lump sum death benefit crystallises, and the continuing income stream belongs to the successor rather than the deceased's estate.

Income tax treatment follows the age-75 binary: if the original annuitant dies before age 75, successor income payments are tax-free; if death occurs at or after age 75, successor income is taxable at the recipient's marginal rate.⁸ This creates distinct planning considerations for clients of different ages.

2.2 Guaranteed Periods: Non-Discretionary IHT Exposure

Guaranteed periods ensure annuity payments continue for a minimum term regardless of the member's survival. Since April 2015, no maximum restriction applies — advisors may encounter guarantees extending 20 years or beyond.⁹ Upon the member's death within the guarantee period, payments continue to nominated beneficiaries until the guarantee expires.

The IHT position requires careful analysis. Guaranteed period payments passing via the deceased's will or intestacy rules have always been potentially within the IHT estate. HMRC's Inheritance Tax Manual confirms that where guaranteed instalments pass to the estate, their value forms part of the taxable estate.¹⁰ The April 2027 changes do not fundamentally alter this position for non-discretionary guaranteed periods, though they bring discretionary arrangements into scope.

Valuation methodology proves critical. HMRC does not simply aggregate outstanding instalments; instead, it determines current open market value — what a purchaser would pay for the remaining income stream. For straightforward cases, HMRC provides an Inheritance Tax Guaranteed Annuity Calculator. Complex situations require referral to HMRC's Actuarial Team.¹⁰ A guarantee of £15,000 per annum for six remaining years might yield an actuarial value of approximately £60,000, not £90,000.

2.3 Value Protection: Capital Preservation with Tax Implications

Value protection (annuity protection lump sum death benefit) returns the difference between the annuity purchase price and total payments received to date. The calculation follows the statutory formula: AC - AP - TPLS, where AC represents the scheme pension or lifetime annuity purchase price, AP represents total pension or annuity payments made to the member from 6 April 2006 onward, and TPLS represents any annuity protection lump sums previously paid.¹¹

Example: A member purchases a £200,000 annuity generating £12,000 annually. After eight years (£96,000 received), death triggers a value protection payment of £104,000 (£200,000 minus £96,000). No restriction applies based on the member's age at death.

Value protection arrangements have always carried potential IHT exposure where the estate is entitled to payment (non-discretionary direction). Discretionary value protection arrangements currently benefit from exclusion from the taxable estate under existing rules, but this favourable treatment ends in April 2027.³ Advisors must verify whether existing client arrangements operate on discretionary or non-discretionary bases.

For deaths before age 75, value protection lump sums are tax-free up to the deceased's available Lump Sum and Death Benefit Allowance (LSDBA), with any excess taxed at the recipient's marginal income tax rate. For deaths at or after age 75, the entire payment is taxable at marginal rates.¹²

2.4 Nominee and Successor Annuities

The April 2015 pension flexibilities expanded death benefit options to include nominee and successor annuities. These standalone annuities, purchased at the member's retirement, become payable to a nominated individual upon death. Unlike joint life arrangements, nominee annuities may terminate upon the beneficiary's remarriage, civil partnership formation, or death.¹³

Nominee annuities can provide flexible beneficiary designation beyond spouses and civil partners. However, the purchase mechanism differs from joint life: funds are used to purchase a separate annuity for the nominee, rather than continuing an existing income stream. This distinction affects both pricing and availability — not all providers offer nominee annuity facilities.

Income tax treatment mirrors joint life arrangements: tax-free income if the original annuitant died under age 75, taxable at marginal rates if death occurred at or after 75.⁸ The two-year payment window applies for pre-75 deaths; payments must commence within two years to preserve tax-free status.

2.5 Section 32 Plans and Retirement Annuity Contracts: Structural Constraints

Legacy pension structures present particular challenges. Section 32 buyout policies and retirement annuity contracts (RACs) must use direction (non-discretionary beneficiary designation) unless a trust structure is established.¹⁴ This structural requirement creates automatic IHT exposure for death benefits, as non-discretionary arrangements fall within the deceased's estate.

Advisors encountering clients with Section 32 or RAC annuities should assess whether trust arrangements were established at purchase and verify current beneficiary designation mechanics. The absence of discretionary provisions means April 2027 does not change the fundamental IHT position — these arrangements have always been potentially in-scope — but it does eliminate any residual uncertainty about treatment.

3. Income Tax Treatment: The Age-75 Cliff Edge

3.1 The Binary Framework

UK pension taxation applies a fundamental binary to death benefits based on the member's age at death. The age-75 threshold creates distinct planning windows that interact with IHT considerations in complex ways.

Death Age	Income Payments (Joint/Nominee/Successor/Guarantee)	Lump Sum (Value Protection)
Before 75	Tax-free	Tax-free up to LSDBA; excess at marginal rate
75 or older	Taxable at recipient's marginal rate	Taxable at marginal rate (no LSDBA testing)

This framework applies regardless of the recipient's age or relationship to the deceased. A 40-year-old child receiving successor annuity income following parental death at age 72 receives that income tax-free; the same child receiving income following parental death at age 76 pays income tax at their marginal rate.⁸

3.2 The Two-Year Payment Window

For deaths before age 75, a critical timing requirement applies. Income death benefits from pre-age 75 deaths must be designated or settled within two years of the scheme administrator becoming aware of the death. Failure to meet this deadline triggers income tax liability at the recipient's marginal rate, eliminating the age-based advantage.⁹

This requirement creates operational complexity for personal representatives and beneficiaries, particularly in contested estates or where death notification is delayed. Advisors should ensure clients understand the importance of timely communication with pension providers and beneficiary designation clarity.

3.3 Lump Sum and Death Benefit Allowance Mechanics

From 6 April 2024, the Lifetime Allowance was replaced by two new limits: the Lump Sum Allowance (LSA) of £268,275 for tax-free cash withdrawals, and the Lump Sum and Death Benefit Allowance (LSDBA) of £1,073,100 for all tax-free lump sums including death benefits.¹⁵

For deaths before age 75, value protection lump sums test against the deceased's remaining LSDBA. If the deceased had already used LSDBA during lifetime (through tax-free cash withdrawals, for example), the available death benefit allowance is correspondingly reduced. Excess amounts above available LSDBA are taxed at the recipient's marginal income tax rate, not the previous 55% Lifetime Allowance charge.¹⁶

For deaths at or after age 75, LSDBA testing does not apply — the entire lump sum is simply taxed at the recipient's marginal rate. This creates scenarios where post-75 death may actually produce lower overall tax charges than pre-75 death with LSDBA excess.

3.4 Worked Example: LSDBA Interaction

Consider a client who purchased a £300,000 annuity at age 65 having previously taken £200,000 tax-free cash (using £200,000 of their £268,275 LSA). Their LSDBA is reduced by the same £200,000 to £873,100.

If the client dies at age 72 having received £42,000 in annuity payments, value protection produces a £258,000 lump sum. This tests against the £873,100 available LSDBA — well within limits, so the entire amount passes tax-free.

Had the client instead taken their full LSA (£268,275) plus additional tax-free lump sums totalling £500,000 over their lifetime, LSDBA would be reduced to £573,100. The £258,000 value protection payment would still fall within limits.

4. Inheritance Tax Position: Current and Post-April 2027

4.1 Current Framework: The Discretionary Distinction

The current IHT treatment of pension death benefits hinges on whether benefits pass under discretionary or non-discretionary arrangements. Section 151 of the Inheritance Tax Act 1984 provides that an interest in a registered pension scheme ending on death is left out of account for IHT purposes where benefits are paid at the discretion of scheme trustees or administrators.¹⁷ Expression of wish forms nominating beneficiaries do not bind the scheme — trustees retain ultimate discretion — and this preserves IHT exemption.¹⁰

Non-discretionary arrangements (binding directions) have always potentially fallen within the taxable estate. This includes:

• Guaranteed period payments where the estate is entitled
• Value protection lump sums directed to specific recipients
• Section 32 and RAC death benefits without trust structures
• Any arrangement where the member's direction binds the paying party

4.2 April 2027: What Changes

From 6 April 2027, most unused pension funds and death benefits will be included within the value of an individual's estate for IHT purposes.³ The change specifically brings discretionary pension death benefits — previously excluded — into the taxable estate. This represents a fundamental policy shift, ending the IHT advantage that made pension funds attractive for wealth preservation purposes.

Benefits falling into scope include:

• Uncrystallised funds lump sum death benefits
• Drawdown lump sum death benefits
• Flexi-access drawdown fund lump sums
• Annuity protection lump sum death benefits (discretionary arrangements)
• Remaining pension instalments with guaranteed minimum payments (discretionary arrangements)
• Pension protection lump sum death benefits from defined benefit schemes
• Discretionary death benefits generally

4.3 What Remains Excluded

Not all pension death benefits fall within the April 2027 scope. Explicitly excluded categories include:

• Joint life annuities — the standout planning opportunity
• Death-in-service benefits payable from registered pension schemes
• Dependants' scheme pensions from defined benefit and collective money purchase arrangements
• Benefits passing to surviving spouses or civil partners (spousal exemption)
• Benefits passing to registered charities (charitable exemption)⁴

The joint life annuity exclusion merits particular attention. Unlike guaranteed periods or value protection (which may fall in-scope depending on discretionary status), joint life arrangements are categorically excluded regardless of how successor payments are directed.

4.4 Reporting and Payment Mechanics

The government's consultation process (649 written responses, 9 workshops) produced significant changes to the originally proposed liability framework.¹⁸ Key outcomes include:

Personal representative liability: Personal representatives — not pension scheme administrators — bear responsibility for reporting and paying IHT on pension death benefits. This reverses the Budget 2024 proposal that would have placed liability on schemes.

Six-month deadline: The standard IHT reporting and payment deadline of six months from date of death applies to pension death benefits.

Information provision: Pension scheme administrators must inform personal representatives of death benefit values within four weeks of receiving death notification.

Payment flexibility: Beneficiaries may pay IHT from the wider estate, direct pension scheme administrators to pay HMRC directly, or pay directly themselves.

These mechanics create practical complexities for estate administration. Personal representatives must coordinate with potentially multiple pension providers, obtain valuations, include pension values in IHT400 returns, and arrange payment before the six-month deadline.

4.5 Residence-Based IHT Regime Interaction

The residence-based IHT regime enacted from 6 April 2025 adds complexity for internationally mobile clients. Replacing the previous domicile-based system, the new framework applies UK IHT to the worldwide estates of "long-term residents" — individuals UK tax resident for at least 10 of the previous 20 tax years.¹⁹

Tail provisions extend IHT exposure for 3-10 years after leaving the UK, depending on prior residence duration. This affects clients with UK pension annuities who relocate abroad: their worldwide estate (including non-UK assets) may remain subject to UK IHT if they meet the long-term resident test.

For UK annuity death benefits specifically, the interaction between residence-based IHT rules and post-April 2027 pension taxation requires careful analysis. A formerly UK-resident individual whose annuity value protection payment crystallises while they remain within the tail period would see that benefit included in their UK-taxable estate.

5. Practical Structuring Guidance

5.1 Scenario Analysis: Matching Structure to Objectives

Scenario A: Guaranteed income and IHT efficiency

A 66-year-old client prioritises secure retirement income with spouse protection after death. Estate planning considerations are secondary but relevant; the client wishes to minimise IHT exposure where possible.

Recommended approach: Joint life annuity with 50-100% continuation rate. The structure provides guaranteed income for both lives while explicitly avoiding April 2027 IHT inclusion. Income passing to the surviving spouse remains tax-free if death occurs before age 75, or taxable at the survivor's marginal rate thereafter. No estate valuation complications arise.⁴

Scenario B: Capital protection priority

A 68-year-old single client with adult children wants to maximise capital return to beneficiaries if death occurs early. Income security during lifetime is important but secondary to intergenerational wealth transfer.

Recommended approach: Value protection annuity with careful IHT planning. The structure returns unused capital to beneficiaries, but advisors must confirm whether arrangements operate on discretionary or binding bases. Non-discretionary value protection has always been potentially IHT-exposed; discretionary arrangements lose their exemption from April 2027. Given the client's objectives, a combination strategy — partial annuity with value protection, partial drawdown retention — may better serve both income and estate planning goals.

Scenario C: Non-spouse beneficiary designation

A 70-year-old widowed client wishes to provide for an adult child with disabilities. The child receives means-tested benefits, and direct income could affect entitlement.

Recommended approach: This scenario requires careful coordination between pension, trust, and benefits planning. A nominee annuity directly payable to the child may affect benefit entitlements. Alternative structures — including discretionary trusts receiving death benefits, or joint life arrangements with the child as second life — require specialist advice on benefit implications. The April 2027 changes affect IHT treatment of any discretionary trust solutions.

Scenario D: Section 32 or RAC holder

A 63-year-old client holds a Section 32 buyout policy from a former employer's defined benefit scheme. The client is approaching retirement and wishes to understand death benefit options.

Recommended approach: Advisors should first verify whether trust arrangements exist. If the Section 32 operates without trust structure, death benefits are inherently non-discretionary and have always been potentially IHT-exposed.¹⁴ Options include: crystallising to modern personal pension arrangements (where regulations permit); establishing trust arrangements if available; accepting IHT exposure while planning around it; or focusing on joint life annuity purchase at retirement to secure exclusion from estate.

5.2 Decision Framework Summary

Primary Objective	Preferred Structure	IHT Position Post-April 2027	Key Consideration
Spouse income security	Joint life annuity	Excluded	Continuation rate affects pricing
Capital preservation	Value protection	Included (if discretionary)	LSDBA testing for pre-75 deaths
Flexible beneficiary	Nominee annuity	Depends on discretionary status	Provider availability varies
Maximum guarantee	Long guaranteed period	May be included	Actuarial valuation applies
Section 32/RAC optimisation	Joint life at crystallisation	Excluded (for joint life element)	Trust structure assessment needed

5.3 Pre-April 2027 Client Review Priorities

Advisors should systematically review existing annuity client arrangements before April 2027:

1. Identify discretionary versus non-discretionary provisions — request confirmation from annuity providers regarding how death benefits are structured
2. Assess beneficiary designation currency — ensure expression of wish forms reflect current client circumstances
3. Document death benefit options — maintain file records demonstrating that all available options were explained and considered
4. Quantify IHT exposure — for clients with potentially in-scope arrangements, calculate indicative estate values including pension assets
5. Consider restructuring opportunities — where clients have unutilised funds, joint life annuity purchase may offer IHT advantages

6. FCA Compliance Considerations

6.1 TR24/1 Findings and Death Benefit Disclosure

The FCA's March 2024 thematic review of retirement income advice (TR24/1) identified substantial disclosure failings across reviewed files. Particular concerns included inadequate risk profiling, insufficient income withdrawal sustainability analysis, and deficient disclosure of charges, tax implications, and death benefit options.⁵

Death benefit disclosure represents a specific area of regulatory focus. Firms advising on annuity purchases must demonstrate that:

• All available death benefit options were explained and their implications discussed
• Client beneficiary circumstances were understood and documented
• Tax treatment (both income tax and IHT) was clearly communicated
• The choice of death benefit structure (or absence thereof) was appropriate for client circumstances

6.2 COBS 19.9 Requirements

The FCA Handbook's COBS 19.9 provisions mandate specific information disclosure for pension annuity purchases. Firms must provide information about whether income is guaranteed and for how long, payment frequency, whether the annuity covers a single person or includes beneficiary provision, whether income increases over time, how personal circumstances affect retirement income, and enhanced annuity eligibility.²⁰

These requirements apply at point of sale but also inform ongoing advice obligations. Advisors reviewing existing annuity arrangements should verify that original disclosure met these standards and update clients on subsequent regulatory and legislative changes affecting their policies.

6.3 Consumer Duty Fair Value Assessment

Consumer Duty requirements (effective July 2023) impose ongoing fair value obligations on firms advising on or manufacturing annuity products. The price and value outcome rules require that the price a consumer pays is reasonable compared to the overall benefits received.⁶

For annuity death benefits, fair value assessment must consider whether elected options genuinely serve client interests. Value protection purchased at significant premium cost by a client with no realistic expectation of early death and no estate planning objectives may not represent fair value. Conversely, failure to recommend joint life annuity for a client with clear spouse protection objectives could constitute a fair value failing.

Conclusion

The April 2027 inheritance tax reforms fundamentally reshape pension death benefit planning, yet annuities remain strategically viable when properly structured. Joint life annuities emerge as the standout opportunity — explicitly excluded from IHT scope while providing guaranteed successor income. Value protection and guaranteed period arrangements face increased scrutiny as discretionary provisions lose their current IHT exemption.

Advisors operate within a 14-month implementation window requiring systematic client review. Priority actions include verifying discretionary versus non-discretionary status of existing arrangements, updating beneficiary designations, and documenting death benefit option discussions to satisfy TR24/1 expectations. The interaction between age-75 income tax thresholds, LSDBA mechanics, and post-April 2027 IHT rules demands integrated analysis rather than siloed consideration of each tax regime.

The residence-based IHT regime enacted from April 2025 adds complexity for internationally mobile clients, extending UK tax exposure beyond traditional domicile boundaries. Cross-border annuity death benefits require specialist analysis of long-term resident status and tail provision implications.

Positioning annuities as estate planning tools — not merely income solutions — represents both a client service enhancement and a competitive differentiator. Those advisors who master these technical distinctions can guide clients through the April 2027 transition with confidence, ensuring retirement income structures serve both lifetime security and intergenerational wealth transfer objectives.

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CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Retirement Income Planning, Estate Planning, Inheritance Tax, Pension Death Benefits

Learning Objectives

Upon completing this article, practitioners will be able to:

1. Distinguish between joint life annuity, guaranteed period, value protection, and nominee annuity death benefit structures and their respective IHT treatments post-April 2027
2. Apply the age-75 income tax threshold rules and LSDBA mechanics to calculate death benefit tax liabilities for client scenarios
3. Evaluate whether existing client annuity arrangements require restructuring before April 2027 based on discretionary versus non-discretionary provisions
4. Identify FCA disclosure requirements for annuity death benefits under TR24/1 findings and COBS 19.9 provisions

SRA Competency Mapping

• A2: Technical legal practice — application of pension and tax legislation to client advisory scenarios
• A4: Research, analysis and assessment — evaluation of regulatory developments affecting client outcomes

Reflective Questions

1. How would current client review processes need to adapt to systematically identify discretionary versus non-discretionary annuity death benefit provisions before April 2027?
2. What additional documentation standards should be implemented to demonstrate TR24/1-compliant death benefit disclosure in annuity recommendation files?
3. How might the joint life annuity IHT exemption influence retirement income recommendations for clients with significant estate planning concerns?

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Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-06. 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.

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Related Articles

• Pension Death Benefits: Tax Treatment and Client Communication
• Pensions and Estate Planning: Death Benefit Tax Rules and Nomination Strategy
• Post-Death Tax Planning: Opportunities Your Clients (and You) Are Missing
• Expression of Wish Forms: Advisor Liability and Best Practice Guidance in the Pension IHT Era
• FCA Consumer Duty and Estate Planning Services: What Advisors Must Do

Footnotes

Footnotes

1. FCA Retirement Income Market Data 2024/25. https://www.fca.org.uk/data/retirement-income-market-data-2024-25 ↩

2. Which? Best Annuity Rates UK February 2026. https://www.which.co.uk/money/pensions-and-retirement/accessing-your-pensions/annuities/annuity-rates-aQGfH6W5n2rm ↩

3. GOV.UK — Inheritance Tax on 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 ↩ ↩² ↩³

4. Royal London — IHT on Pension Death Benefits from April 2027. https://adviser.royallondon.com/technical-central/pensions/death-benefits/inheritance-tax-on-pension-death-benefits-from-april-2027/ ↩ ↩² ↩³ ↩⁴

5. FCA Thematic Review TR24/1 (March 2024). https://www.fca.org.uk/publication/thematic-reviews/tr24-1.pdf ↩ ↩²

6. Legal & General — Consumer Duty. https://www.legalandgeneral.com/adviser/annuities/adviser-academy/consumer-duty/ ↩ ↩²

7. M&G Wealth Adviser — Annuity Death Benefits. https://www.mandg.com/wealth/adviser-services/tech-matters/pensions/death-benefits/annuity-death-benefits ↩

8. PTM072210 — Income Tax Treatment of Beneficiary Annuities. https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm072210 ↩ ↩² ↩³

9. PTM072200 — Beneficiary's Annuity. https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm072200 ↩ ↩²

10. IHTM17054 — Payments Continuing After Death. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm17054 ↩ ↩² ↩³

11. PTM073400 — Annuity Protection Lump Sum Death Benefit. https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm073400 ↩

12. Royal London — Lump Sum and Death Benefit Allowances from April 2024. https://adviser.royallondon.com/technical-central/pensions/benefit-options/Lump-sum-and-lump-sum-death-benefit-allowances-from-April-2024/ ↩

13. Finance Act 2004, Section 167. https://www.legislation.gov.uk/ukpga/2004/12/section/167 ↩

14. Royal London — Death Benefits Discretion and Nomination. https://adviser.royallondon.com/technical-central/pensions/death-benefits/death-benefits-discretion-and-how-to-nominate-a-beneficiary/ ↩ ↩²

15. GOV.UK — Lifetime Allowance Guidance Newsletter March 2024. https://www.gov.uk/government/publications/lifetime-allowance-guidance-newsletter-march-2024/lifetime-allowance-guidance-newsletter-march-2024 ↩

16. Royal London — Lump Sum and Death Benefit Allowances from April 2024. https://adviser.royallondon.com/technical-central/pensions/benefit-options/Lump-sum-and-lump-sum-death-benefit-allowances-from-April-2024/ ↩

17. Inheritance Tax Act 1984, Section 151 — Pension Scheme Interests. https://www.legislation.gov.uk/ukpga/1984/51/section/151 ↩

18. GOV.UK — IHT on Pensions: Summary of Responses. 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 ↩

19. GOV.UK — Technical Amendments to the Residence-Based Tax Regime. https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩

20. FCA Handbook — COBS 19.9. https://www.handbook.fca.org.uk/handbook/COBS/19/9.html ↩