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Estate Planning in Year-End Tax Planning: A Comprehensive Accountant's Approach

· 19 min

Executive Summary

Year-end tax planning is the accountant's most effective delivery mechanism for estate planning advice, yet most practices treat inheritance tax as a separate specialist referral rather than embedding it within the annual compliance cycle. The 2025-26 year-end is uniquely consequential: IHT receipts reached a record GBP 8.2 billion in 2024-25, with GBP 7.1 billion collected in the first ten months of 2025-26.12 The residence-based IHT regime enacted from 6 April 2025 has replaced the domicile-based system.3 Agricultural property relief and business property relief reforms from 6 April 2026 cap 100% relief at GBP 2.5 million, with 50% relief thereafter.4 Business Asset Disposal Relief rises from 14% to 18% from April 2026, and pension death benefits enter the IHT scope from April 2027.56 This article provides a structured multi-tax framework enabling accountants to integrate IHT, CGT, and income tax planning within standard year-end client reviews.

1. The Year-End Estate Planning Imperative

The fiscal context for estate planning has shifted from specialist concern to mainstream accountancy advisory. IHT receipts reached GBP 8.2 billion in 2024-25, a record representing a GBP 750 million increase on the prior year.1 Provisional data for April 2025 to January 2026 shows GBP 7.1 billion collected in ten months, GBP 0.1 billion ahead of the same period in 2024-25.2 The Office for Budget Responsibility forecasts IHT receipts will reach GBP 14.5 billion by 2030-31, a 67% increase over five years, driven by frozen thresholds, rising asset values, and the inclusion of pension death benefits from 2027.7

The nil-rate band has been frozen at GBP 325,000 since 2009-10, with the residence nil-rate band fixed at GBP 175,000. Both freezes have been extended to 2030-31 via the Finance Bill 2025-26.8 Fiscal drag is the predictable consequence: each year of asset price growth, however modest, pushes more estates above the IHT threshold without any change in the legislative rate. While HMRC estimates that more than 90% of estates will continue to have no IHT liability, the concentration of IHT exposure among entrepreneurial, property-owning, and high-income clients means that the typical accountancy practice holds a disproportionate share of affected individuals within its client base.8

HMRC enforcement underscores the compliance imperative. In the year to April 2025, HMRC launched 3,961 IHT investigations, a 41% increase year-on-year.9 Some 7,500 probate cases were questioned for property valuations, and 1,500 families received additional IHT bills.9 For accountants preparing self-assessment returns and managing client wealth, the year-end review represents a natural checkpoint: income records, asset schedules, and capital events are already assembled. The convergence of APR/BPR reform from April 2026, BADR rate increases from the same date, and the penultimate year before pension death benefits enter IHT scope makes the 2025-26 year-end the most consequential estate planning review point in recent memory.

The thesis of this article is straightforward: year-end compliance creates the accountant's structured opportunity for estate planning conversations. Rather than treating IHT as a separate advisory stream requiring specialist referral, practitioners who embed estate planning into the annual review cycle will identify exposure earlier, coordinate across taxes more effectively, and deliver measurably better client outcomes.

2. The Current Inheritance Tax Framework

2.1 Thresholds and Rates

The standard IHT rate is 40% on the chargeable estate above the nil-rate band.10 The combined nil-rate bands for a married couple or civil partners can shield up to GBP 1,000,000 (GBP 325,000 NRB plus GBP 175,000 RNRB, transferable between spouses).8 The RNRB is available where a residence is passed to direct descendants, subject to a taper threshold of GBP 2 million: the RNRB is reduced by GBP 1 for every GBP 2 of estate value above this threshold, extinguishing entirely at GBP 2.35 million for a single individual.8

A reduced IHT rate of 36% applies where 10% or more of the baseline estate is left to qualifying charities under IHTA 1984 Schedule 1A.11 This reduced rate is frequently overlooked in year-end discussions, yet it can yield a net benefit to non-charitable beneficiaries in estates where the charitable threshold is close to being met. The calculation of the baseline estate requires careful consideration, as it excludes exempt transfers (including the spouse exemption) but includes the value of property passing under the nil-rate band.

2.2 The Residence-Based Regime

From 6 April 2025, the Finance Act 2025 replaced the domicile-based IHT system with a residence-based test. An individual is a long-term UK resident for IHT purposes if they have been UK tax resident for at least 10 of the previous 20 tax years.3 An IHT "tail" applies after departure: the minimum tail period is 3 years (for those resident 10-13 years), extending up to 10 years for individuals with 20 or more years of UK residence.12 For individuals under 20, the calculation uses whole tax years alive rather than the standard 20-year lookback.3 Excluded property trusts are now tested against the settlor's long-term UK resident status, not domicile.3

This regime change has direct year-end planning implications. Practitioners advising clients with cross-border connections must reassess IHT exposure based on residence history rather than the previously more subjective domicile analysis. The year-end review is the natural point to confirm residence status for each relevant tax year and update estate exposure calculations accordingly. Where a client's residence status is transitional -- approaching the 10-year threshold or recently departed from the UK -- the year-end analysis should include a forward projection of when IHT status will change and what planning steps are available in the interim.

2.3 Annual Exemptions

The annual IHT gift exemption remains at GBP 3,000 per tax year, with any unused portion carrying forward for one year only.13 Small gifts of up to GBP 250 per recipient per tax year are separately exempt, and marriage or civil partnership gifts are exempt up to GBP 5,000 (from a parent), GBP 2,500 (grandparent or remoter ancestor), or GBP 1,000 (other persons).13 Potentially exempt transfers -- outright gifts to individuals -- become fully exempt if the transferor survives seven years.14 Taper relief reduces the IHT charge on PETs where death occurs between three and seven years after the transfer, though it applies only where cumulative gifts exceed the nil-rate band.15

Year-end is the deadline for utilising the annual exemption, which is lost if not used by 5 April. The one-year carry-forward rule means that a client who has not used their 2024-25 exemption loses it entirely on 6 April 2026. Systematic tracking of annual exemption utilisation should form part of every year-end client review for IHT-exposed estates. For a married couple, the combined annual exemption of GBP 6,000 (plus any carried-forward amounts) represents GBP 42,000 of value removed from the estate over a seven-year PET period, before considering any larger potentially exempt transfers.

3. Inheritance Tax and Capital Gains Tax: The Accountant's Coordination Challenge

3.1 CGT as the Effective Gift Tax

Lifetime gifts of chargeable assets are treated as disposals at market value for CGT purposes under TCGA 1992 s.17, regardless of the consideration received.16 The donor bears the CGT liability on any accumulated gain. For 2025-26, CGT rates stand at 18% (basic rate) and 24% (higher rate) across all asset categories, with Business Asset Disposal Relief available at 14%, rising to 18% from 6 April 2026.5 The annual CGT exempt amount is GBP 3,000 for individuals.5

In contrast, death creates a full CGT base cost uplift to market value at the date of death, with no CGT payable.17 This asymmetry is the central tension in estate planning: a lifetime gift triggers immediate CGT and starts the seven-year PET clock, while retention until death eliminates CGT entirely but leaves the asset within the IHT estate. For assets with substantial embedded gains, the CGT cost of gifting can materially erode or even exceed the projected IHT saving, making retention the more tax-efficient outcome in certain scenarios.

3.2 Modelling the Decision: Gift or Retain

The decision to gift assets during lifetime or retain them until death requires quantified multi-tax analysis. Practitioners should model the CGT cost of gifting against the projected IHT savings, taking into account the donor's age, health, and the probability of surviving the seven-year PET period.

Worked example: Business owner, age 62, higher-rate taxpayer

Consider a business owner holding unquoted trading company shares with a base cost of GBP 200,000 and a current market value of GBP 900,000. The chargeable gain on a lifetime gift would be GBP 700,000.

Option A -- Lifetime gift in 2025-26 (using BADR at 14%): Chargeable gain: GBP 700,000 less GBP 3,000 annual exempt amount = GBP 697,000. CGT at 14% (BADR): GBP 97,580. If the donor survives seven years, the shares are fully outside the IHT estate. IHT saving at 40%: GBP 360,000 (on GBP 900,000). Net benefit: GBP 262,420.

Option B -- Lifetime gift in 2026-27 (using BADR at 18%): CGT on same gain at 18%: GBP 125,460. Net benefit if donor survives seven years: GBP 234,540 -- a reduction of GBP 27,880 compared to gifting in 2025-26.

Option C -- Retain until death: CGT: nil (death uplift). IHT at 40% on GBP 900,000: GBP 360,000 (assuming no other reliefs and estate above NRB).

This analysis demonstrates two critical planning points. First, gifting before 6 April 2026 preserves the lower 14% BADR rate, creating a time-limited planning window.5 Second, the net benefit of gifting depends entirely on survivorship: if the donor dies within seven years, the "triple whammy" applies -- CGT has been paid, the gift is brought back into the IHT estate, and the beneficial death uplift has been forfeited.18 The year-end review is the appropriate point to model these scenarios with current asset valuations and updated health considerations.

3.3 Hold-Over Relief

Hold-over relief under TCGA 1992 s.165 is available for gifts of business assets and for gifts that trigger an immediate IHT charge (such as gifts into relevant property trusts).16 Where claimed, CGT is deferred until the donee disposes of the asset, with the donee acquiring the donor's base cost. This mechanism can resolve the CGT/IHT tension for qualifying business assets, though practitioners should note that gifts into discretionary trusts trigger a lifetime IHT charge at 20% on the value above the available nil-rate band, creating a separate cash flow consideration.18

4. Normal Expenditure Out of Income: The Underutilised Exemption

4.1 The Three Statutory Conditions

The normal expenditure out of income exemption under IHTA 1984 s.21 is potentially the most powerful IHT exemption available, as it is uncapped in value.19 Three conditions must be satisfied: the transfer must be part of the transferor's normal expenditure; it must have been made out of income (determined under normal accountancy rules); and the transferor's standard of living must not have been diminished as a result.20

HMRC's approach to establishing a "normal" pattern typically requires evidence over three to four years of consistent giving.19 The exemption covers a wide range of recurring payments: regular premium life insurance policies, annual gifts to family members, pension contributions for adult children, and regular charitable donations. The critical requirement is regularity and a demonstrable pattern -- ad hoc or irregular gifts, however well-intentioned, are unlikely to qualify.

4.2 Year-End as the Documentation Opportunity

The year-end review creates the natural opportunity to evidence and maintain s.21 claims. Income and expenditure records are already assembled for self-assessment purposes. Practitioners should use form IHT403 as a framework for tracking surplus income, documenting gifting patterns, and confirming that the transferor's standard of living has been maintained.19

Practical structuring for clients with demonstrable surplus income might include establishing standing orders for regular family gifts, regular premium whole-of-life or term assurance policies written in trust, and annual pension contributions for family members within the annual allowance. The year-end checkpoint ensures that the pattern remains documented and evidenced. Where a client's income has declined in the current year -- through retirement, business downturn, or changed circumstances -- the practitioner should reassess whether the exemption conditions continue to be met and adjust the gifting programme accordingly. Maintaining a contemporaneous surplus income calculation each year, cross-referenced to the self-assessment return, provides the most robust evidential basis for a future s.21 claim.

5. The April 2026 Convergence: Agricultural Property Relief and Business Property Relief Reform

5.1 The New Relief Structure

From 6 April 2026, APR and BPR are reformed with a combined allowance of GBP 2.5 million for 100% relief, with 50% relief applying on qualifying assets above that threshold (producing an effective IHT rate of 20%).4 This represents the confirmed position following the December 2025 announcement, which increased the allowance from the GBP 1 million originally announced in October 2024.4 Unused allowance transfers to a surviving spouse or civil partner from April 2026.4

AIM-listed shares receive reduced treatment: relief is capped at 50% in all cases, and these holdings do not benefit from the GBP 2.5 million allowance.4 An extended instalment option permits payment of IHT on qualifying APR/BPR property over 10 years, interest-free.4

Transitional rules apply for gifts of qualifying property made between 30 October 2024 (Budget day) and 5 April 2026. The relief available on such gifts, if they become chargeable due to death within seven years, is determined under the new rules rather than the old 100% relief regime.21 Trust provisions include a matching GBP 2.5 million allowance, with caps on relevant property charges for trusts holding excluded property at 30 October 2024.22

5.2 Year-End Planning Actions

The 2025-26 year-end demands specific actions for clients holding qualifying agricultural or business property. Practitioners should review the market value of all qualifying assets against the GBP 2.5 million threshold. Clients with qualifying property materially above this figure face a new IHT exposure from April 2026 that did not previously exist.

Will amendments may be necessary to preserve the spousal transfer of unused allowance. Where existing wills leave qualifying property outright to a surviving spouse, the survivor's own allowance may be sufficient, but where property passes into trust or to other beneficiaries, careful structuring is required to ensure the transferable allowance is not wasted.

For business owners considering lifetime transfers before the reform takes effect, the BADR rate increase from 14% to 18% creates a parallel urgency.5 As demonstrated in the worked example above, gifting business assets in 2025-26 preserves the 14% BADR rate on any chargeable gains. After 5 April 2026, both the APR/BPR regime and the CGT cost of gifting shift against the taxpayer simultaneously.

6. Pension Death Benefits: Preparing for April 2027

From 6 April 2027, unused pension funds and most pension death benefits will be included within the IHT estate value.6 Personal representatives, not scheme administrators, will be liable for reporting and paying the IHT due.6 Excluded from the new rules are death-in-service benefits from registered schemes and dependant's scheme pensions from defined benefit or career average arrangements.6

The fiscal impact is substantial. An estimated 10,500 estates will become newly liable for IHT, with 38,500 existing liable estates paying increased IHT, at an average increase of approximately GBP 34,000 per estate.6 The Exchequer impact is forecast at GBP 710 million in 2027-28, rising to GBP 1,665 million by 2030-31.6

For accountants, the 2025-26 year-end represents the penultimate opportunity to review pension structures before this change takes effect. Pension drawdown sequencing -- the order in which different pension pots and other assets are drawn down in retirement -- has direct IHT consequences once pensions enter the estate. Clients with substantial defined contribution pension funds may benefit from reviewing expression-of-wish nominations and coordinating pension drawdown strategy with wider estate planning objectives. Practitioners should note the professional boundary: the tax analysis of pension drawdown sequencing falls within the accountant's competence, while investment decisions within pension arrangements require referral to a regulated financial advisor.

A practical mechanism introduced in the consultation allows personal representatives to direct scheme administrators to withhold up to 50% of pension death benefits for up to 15 months, providing a payment window for the IHT liability.6 Practitioners advising executors will need to integrate this withholding mechanism into their post-death administration workflows from April 2027 onward.

7. Charitable Giving and the 36% Reduced Rate

The interaction between charitable giving, income tax, and IHT is a further year-end coordination opportunity. The 36% reduced IHT rate applies where 10% or more of the baseline estate is left to qualifying charities under IHTA 1984 Schedule 1A.11 In certain estate configurations, increasing a charitable legacy to meet the 10% threshold can produce a net benefit to non-charitable beneficiaries through the 4 percentage point reduction in the IHT rate on the entire chargeable estate.

Where a client dies without having met the 10% threshold, a deed of variation under IHTA 1984 s.142 permits beneficiaries to redirect a legacy to charity within two years of death, provided the instrument contains the required statement of intent and no consideration in money or money's worth is given.2324 Practitioners involved in post-death tax reporting should assess whether a variation to achieve the 36% rate would benefit all parties.

Within the year-end income tax review, Gift Aid donations interact with estate values: higher-rate tax relief reduces the effective cost of charitable giving during lifetime, while regular charitable payments may qualify for the normal expenditure out of income exemption under s.21. Integrating these considerations within the year-end review ensures that charitable giving serves both income tax efficiency and estate value management simultaneously.

8. Building the Year-End Estate Planning Checklist

The preceding analysis yields a structured framework that practitioners can embed within their standard year-end client review process.

Annual exemptions and gifts: Confirm whether the GBP 3,000 annual exemption has been utilised for 2025-26. Identify any unused 2024-25 exemption eligible for carry-forward before 6 April 2026. Review small gift exemptions (GBP 250 per recipient) and marriage exemptions where applicable.13

Normal expenditure out of income: Assess whether the client has demonstrable surplus income. Review and document the regularity and pattern of gifts made from income during the year. Confirm that the client's standard of living has been maintained. Update form IHT403 records.19

CGT/IHT coordination: Review assets held with significant unrealised gains. Model the CGT cost of lifetime gifting against projected IHT savings, particularly for business assets qualifying for BADR at 14% in 2025-26.5 Assess hold-over relief availability for qualifying business asset transfers.16

APR/BPR reform preparation: Value all qualifying agricultural and business property against the GBP 2.5 million threshold. Review will provisions to ensure spousal transfer of unused allowance is preserved. Consider timing of lifetime transfers before 6 April 2026.4

Pension position: Review pension fund values and expression-of-wish nominations in preparation for April 2027 inclusion in IHT estates. Assess how pension drawdown sequencing affects estate value management. Refer investment decisions to regulated financial advisors where appropriate.6

Charitable giving: Assess whether the client's estate is close to the 10% charitable threshold for the 36% reduced IHT rate. Review Gift Aid claims for income tax efficiency. Identify regular charitable payments that may qualify under the normal expenditure exemption.11

Residence status: For clients with cross-border connections, confirm long-term UK resident status under the new 10-of-20-year test enacted from April 2025. Update IHT exposure calculations where residence history has changed.3

Trust compliance: Confirm Trust Registration Service entries are up to date for any trusts within the client's estate planning structure. Review 10-year anniversary charge and exit charge reporting obligations.25

Making Tax Digital touchpoints: For clients entering MTD for Income Tax from April 2026, quarterly digital submissions create four additional annual touchpoints for estate planning review.26 Practices should build estate planning prompts into their quarterly MTD workflows, ensuring that asset disposals and income changes flagged through quarterly reporting trigger a reassessment of the client's estate position.

Cross-referral assessment: Identify matters requiring referral to solicitors (will amendments, trust establishment), IFAs (pension investment decisions), or specialist tax counsel (complex cross-border arrangements, HMRC disputes). Document referral rationale and follow-up actions.

The accountant who systematically works through this framework at each year-end will identify emerging IHT exposure that might otherwise remain undetected until death, when planning opportunities have been exhausted. The convergence of legislative changes between 2025 and 2027 makes this integration not merely desirable but professionally necessary. Estate planning is no longer an optional advisory overlay; it is a core competency within the year-end tax planning process.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Tax Planning, Estate Planning, Client Advisory, Compliance

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the key annual IHT exemptions and their year-end utilisation requirements, including the GBP 3,000 annual exemption carry-forward rule and normal expenditure out of income conditions
  2. Evaluate the CGT cost of lifetime gifting against projected IHT savings using current 2025-26 rates, including the impact of the BADR increase from 14% to 18% from April 2026
  3. Apply the normal expenditure out of income exemption (IHTA 1984 s.21) conditions within a year-end client review, using income and expenditure records to document and evidence qualifying patterns
  4. Analyse the impact of APR/BPR reform (GBP 2.5 million combined allowance from April 2026) and pension death benefit inclusion (from April 2027) on year-end estate planning decisions for business owner and high-net-worth clients

Competency Mapping

  • ICAEW Code of Ethics: Professional Competence and Due Care (Section 113)
  • PCRT Standards: Standard for Tax Planning (Professional Conduct in Relation to Taxation)
  • AAT Professional Competency: Tax Planning and Compliance

Reflective Questions

  1. How would the integration of estate planning into the standard year-end review process affect client advisory capacity within the practice?
  2. What documentation protocols could be implemented to evidence normal expenditure out of income claims during annual compliance work?
  3. How should the April 2026 convergence of APR/BPR reform and BADR increases influence current year-end planning recommendations for business owner clients?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 24 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

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

Footnotes

Footnotes

  1. HMRC Tax Receipts and National Insurance Contributions Monthly Bulletin (April 2025). 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 ↩ ↩2

  2. HMRC Tax Receipts Monthly Bulletin -- January 2026 edition (February 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 ↩ ↩2

  3. Finance Act 2025 c.8 Part 2 Chapter 4: Inheritance Tax -- Long-term UK resident. https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩ ↩2 ↩3 ↩4 ↩5

  4. GOV.UK: Agricultural property relief and business property relief changes (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  5. GOV.UK: Capital Gains Tax rates and allowances (2025-26). https://www.gov.uk/guidance/capital-gains-tax-rates-and-allowances ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. GOV.UK: Inheritance Tax -- unused pension funds and death benefits (December 2025). 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 ↩5 ↩6 ↩7 ↩8

  7. GOV.UK: Budget 2025 document -- OBR fiscal forecasts. https://www.gov.uk/government/publications/budget-2025-document/budget-2025-html ↩

  8. GOV.UK: Inheritance Tax thresholds (as updated for Finance Bill 2025-26). https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩ ↩2 ↩3 ↩4

  9. NFU Mutual Freedom of Information data on HMRC IHT investigations, as reported in MoneyWeek (2025) and Today's Wills and Probate (2025). https://moneyweek.com/personal-finance/inheritance-tax/inheritance-tax-investigations; https://todayswillsandprobate.co.uk/hmrc-open-up-extra-1000-iht-investigations-over-the-last-12-months/ ↩ ↩2

  10. Inheritance Tax Act 1984 Schedule 1 (Table of Rates of Tax). https://www.legislation.gov.uk/ukpga/1984/51/schedule/1 ↩

  11. HMRC Inheritance Tax Manual IHTM45001: Reduced rate for gifts to charity. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm45001 ↩ ↩2 ↩3

  12. KPMG: Inheritance Tax changes from 6 April 2025 -- an update. https://kpmg.com/uk/en/insights/tax/inheritance-tax-changes-from-6-april-2025-an-update.html ↩

  13. GOV.UK: Inheritance Tax -- Rules on giving gifts. https://www.gov.uk/inheritance-tax/gifts ↩ ↩2 ↩3

  14. Inheritance Tax Act 1984 Section 3A: Potentially exempt transfers. https://www.legislation.gov.uk/ukpga/1984/51/section/3A ↩

  15. HMRC Inheritance Tax Manual IHTM14612: Taper relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14612 ↩

  16. Taxation of Chargeable Gains Act 1992 Section 17: Market value rule for non-arm's length disposals. https://www.legislation.gov.uk/ukpga/1992/12/section/17 ↩ ↩2 ↩3

  17. GOV.UK: HS282 Death, personal representatives and legatees (2025). https://www.gov.uk/government/publications/death-personal-representatives-and-legatees-hs282-self-assessment-helpsheet/hs282-death-personal-representatives-and-legatees-2025 ↩

  18. Kingsley Napley: IHT and CGT -- uncomfortable bedfellows? https://www.kingsleynapley.co.uk/insights/blogs/private-client-law-blog/iht-and-cgt-uncomfortable-bedfellows-dont-overlook-possible-capital-gains-tax-exposure-in-your-inheritance-tax-planning ↩ ↩2

  19. HMRC Inheritance Tax Manual IHTM14231: Normal expenditure out of income -- introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14231 ↩ ↩2 ↩3 ↩4

  20. HMRC Inheritance Tax Manual IHTM14255: Normal expenditure out of income -- conditions. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14255 ↩

  21. AccountingWEB: How transitional rules on IHT reliefs affect gifts (2025). https://www.accountingweb.co.uk/tax/hmrc-policy/how-transitional-rules-on-iht-reliefs-affect-gifts ↩

  22. GOV.UK: Agricultural property relief and business property relief changes -- trust provisions (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  23. Inheritance Tax Act 1984 Section 142: Alteration of dispositions taking effect on death. https://www.legislation.gov.uk/ukpga/1984/51/section/142 ↩

  24. HMRC Inheritance Tax Manual IHTM35028: Statement of Intent for instruments of variation. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm35028 ↩

  25. HMRC Trust Registration Service Manual TRSM10020. https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm10020 ↩

  26. GOV.UK: Check if you're eligible for Making Tax Digital for Income Tax (2025). https://www.gov.uk/guidance/check-if-youre-eligible-for-making-tax-digital-for-income-tax ↩

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