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Inheritance Tax Nil-Rate Band Transfers: Technical Guide for Accountants

· 19 min

Executive Summary

The transferable nil-rate band under IHTA 1984 ss.8A-8C remains one of the most consequential reliefs available in inheritance tax planning, yet its percentage-based mechanics generate persistent technical complexity. With the NRB frozen at GBP 325,000 through 2029-30 and IHT receipts reaching GBP 7.1 billion in the first ten months of 2025-26, correct TNRB claims deliver material tax savings that compound in value with each year of fiscal drag.12 Three concurrent legislative developments demand updated technical analysis: the residence-based IHT regime replacing domicile from 6 April 2025, pension death benefit inclusion from April 2027 pushing more estates above the RNRB taper threshold, and APR/BPR allowance restructuring from April 2026 creating new interactions with NRB planning.34 This article provides accountants with a comprehensive technical framework encompassing calculation methodology, claims procedure, and analysis of complex scenarios including legacy NRB discretionary trusts and historical deaths.

1. Introduction: The Fiscal Context for TNRB Claims

The nil-rate band has been frozen at GBP 325,000 since 6 April 2009. Finance Act 2025 extended this freeze through 2029-30, with further legislation in Finance Bill 2025-26 to extend it to 2030-31.5 Had the NRB kept pace with CPI since 2009, it would exceed GBP 500,000 by the end of the freeze period.6 This prolonged fiscal drag has significantly expanded the IHT net: HMRC data for 2022-23 confirms 31,500 estates incurred IHT charges, representing 4.62% of UK deaths -- a 13% increase from 2021-22, with total IHT liabilities of GBP 6.70 billion.7

Against this backdrop, the transferable nil-rate band represents one of the most reliable mechanisms for reducing IHT exposure on the second death. A successful claim for the full 100% TNRB doubles the available NRB to GBP 650,000 -- a tax saving of up to GBP 130,000 at the 40% rate. The Office for Budget Responsibility forecasts IHT receipts of GBP 8.7 billion for 2025-26, underscoring the revenue significance of a tax that now touches its joint-highest proportion of estates since 2016-17.8

For accountants administering estates and advising on IHT planning, the TNRB demands technical precision. The percentage-based calculation, the interaction with lifetime transfers, the procedural time limits, and the complications arising from historical deaths, multiple marriages, and legacy will structures all present areas where errors carry direct financial consequences. The enactment of the residence-based IHT regime from 6 April 2025, the forthcoming inclusion of pension death benefits in the IHT net from April 2027, and the restructuring of APR/BPR relief from April 2026 each create new analytical dimensions that practitioners must integrate into their TNRB assessments.349

2. Legislative Framework: IHTA 1984 ss.8A-8C

The transferable nil-rate band was introduced by Finance Act 2008, s.10, Schedule 4, paragraph 2, which inserted sections 8A, 8B, and 8C into the Inheritance Tax Act 1984.1011 The provisions apply where the surviving spouse or civil partner dies on or after 9 October 2007. The first death can have occurred at any date, including under Estate Duty (pre-13 March 1975) or Capital Transfer Tax (13 March 1975 to 17 March 1986).12

2.1 Core Mechanism: Section 8A

Section 8A establishes the eligibility conditions and calculation formula. Where a person ("the deceased") dies having had a spouse or civil partner who predeceased them, and the predeceased spouse had unused nil-rate band at death, a claim may be made to increase the survivor's NRB.10

The statute defines "unused nil-rate band" through two variables:

  • M: the maximum value that could be transferred at the nil per cent rate at the first death (the NRB at that date)
  • VT: the value actually transferred by chargeable transfer on the first death

Where M exceeds VT, there is an excess (E) available for transfer. If no chargeable transfer was made on the first death -- as is common where everything passed to the surviving spouse under the spouse exemption -- VT is nil and the full NRB is available.10

The percentage increase is calculated under s.8A(4) as:

(E / NRBMD) x 100

where NRBMD is the nil-rate band maximum at the date of the first death. This percentage is then applied to the NRB at the date of the survivor's death -- a critical distinction, since the relevant NRB may differ significantly from the NRB at the first death.13

2.2 The 100% Cap: Section 8A(5)

Where the survivor has been married to more than one spouse (or been in more than one civil partnership), unused NRB percentages from each predeceased spouse may be aggregated. However, s.8A(5) imposes a ceiling: the aggregate increase cannot exceed the NRB maximum at the survivor's death.14 In practical terms, the maximum transferable percentage is 100%, giving the survivor a total NRB of twice the prevailing threshold. Accountants advising clients with multiple prior marriages must calculate whether existing transferred percentages already exhaust the available uplift.

2.3 Claims Procedure: Section 8B

Section 8B governs the procedural requirements for making TNRB claims. The claim is made by the personal representatives of the survivor's estate and must be accompanied by prescribed evidence relating to the first death.15 The detailed procedural requirements are addressed in Section 4 below.

3. Calculating the Transferable Percentage

HMRC guidance at IHTM43020 provides the detailed calculation methodology, requiring the percentage to be expressed to four decimal places.13 Precision matters: rounding errors on large estates can translate into significant tax differences. The following worked examples illustrate the calculation under different scenarios.

3.1 Worked Example: Partial NRB Usage on First Death

John dies in 2005-06 with an estate valued at GBP 400,000. His will leaves legacies of GBP 100,000 to his children and the residue of GBP 300,000 to his wife Linda (spouse exempt).

  • NRB at first death (2005-06): GBP 275,000
  • M = GBP 275,000
  • VT = GBP 100,000 (chargeable legacies to children)
  • E = GBP 175,000
  • Transferable percentage: (175,000 / 275,000) x 100 = 63.6363%

Linda dies in 2026-27 with an estate valued at GBP 800,000. The NRB at her death is GBP 325,000.

  • Linda's enhanced NRB: GBP 325,000 + (GBP 325,000 x 63.6363%) = GBP 325,000 + GBP 206,818 = GBP 531,818
  • Chargeable estate: GBP 800,000 - GBP 531,818 = GBP 268,182
  • IHT liability: GBP 268,182 x 40% = GBP 107,273

Without the TNRB claim, Linda's chargeable estate would be GBP 475,000 and the IHT liability GBP 190,000 -- a difference of GBP 82,727.13

3.2 Worked Example: Lifetime Transfers by the First Spouse

Where the first spouse made chargeable lifetime transfers (CLTs) within seven years of death, M is reduced by the cumulative value of those transfers, diminishing the transferable percentage.16

David makes a CLT of GBP 50,000 into a discretionary trust in 2002. He dies in 2006-07.

  • NRB at first death (2006-07): GBP 285,000
  • Cumulative CLTs within seven years of death: GBP 50,000
  • M = GBP 285,000 - GBP 50,000 = GBP 235,000
  • VT = nil (estate passes entirely to surviving spouse)
  • E = GBP 235,000
  • Transferable percentage: (235,000 / 285,000) x 100 = 82.4561%

The surviving spouse's enhanced NRB at death in 2026-27: GBP 325,000 + (GBP 325,000 x 82.4561%) = GBP 325,000 + GBP 267,982 = GBP 592,982.16

3.3 Interaction with the Survivor's Lifetime Transfers

A common source of practitioner error concerns the enhanced NRB from TNRB and its interaction with the surviving spouse's own lifetime transfers. The enhanced NRB only applies to the charge on the survivor's death; it does not increase the NRB available against the survivor's own chargeable lifetime transfers.17 However, where a CLT made by the survivor becomes chargeable on their death within seven years, the enhanced NRB does apply to reduce additional tax arising on the failed potentially exempt transfer or CLT. Advisors should ensure estate planning models account for this asymmetry.

4. Claims Procedure and Time Limits

4.1 Form IHT402 and IHT217

Form IHT402 is the primary claim form, filed alongside IHT400 when reporting the survivor's estate to HMRC.18 For excepted estates where the full NRB is available for transfer and no IHT400 is required, form IHT217 may be used with form IHT205 or the online excepted estate return.19 Where the survivor's estate qualifies as an excepted estate with the full TNRB, the estate must not exceed GBP 650,000 (2 x GBP 325,000) under the simplified reporting regime.20

4.2 Time Limits

The claim must be made within the "permitted period" under IHTM43007: 24 months from the end of the month of the survivor's death, or 3 months from the date the personal representatives first acted, whichever is later.21 An officer of HMRC has discretion to extend the permitted period. Late claims by non-personal representatives may be accepted at HMRC's discretion under IHTM43008 and IHTM43009.22 Practitioners should note that reliance on HMRC discretion for late claims is inherently uncertain and should not be treated as a planning assumption.

4.3 Documentation Requirements

Personal representatives must provide evidence from the first death: a copy of the grant of representation or death certificate, a copy of the will (if any), and where applicable, copies of any deed of variation or similar instruments.23 This creates significant practical challenges where the first death occurred decades ago. Accountants should advise clients to retain all relevant documentation and, where documents have been lost, to obtain copies from the Probate Registry or instructing solicitors' archived files. HMRC may accept alternative evidence where original documentation is unavailable, but the burden falls on the personal representatives to demonstrate the NRB position at the first death.

5. Complex Scenarios: Multiple Marriages and Historical Deaths

5.1 Multiple Marriages

Where the survivor has been married more than once, the unused NRB percentages from each predeceased spouse can be aggregated up to the 100% cap under s.8A(5).14

Consider Margaret, who has been widowed twice. Her first husband Henry died in 2003-04 (NRB GBP 255,000), leaving GBP 100,000 to his children and the residue to Margaret. Her second husband Richard died in 2015-16 (NRB GBP 325,000), leaving his entire estate to Margaret.

  • Henry's transferable percentage: (155,000 / 255,000) x 100 = 60.7843%
  • Richard's transferable percentage: (325,000 / 325,000) x 100 = 100.0000%
  • Aggregate: 160.7843% -- but capped at 100%

Margaret's enhanced NRB at her death: GBP 325,000 + GBP 325,000 = GBP 650,000. The excess 60.7843% is lost.14 Where clients have been married multiple times and the first predeceased spouse left substantial chargeable legacies, the cap may already be reached by the second spouse's unused NRB. Accountants should calculate the aggregate position before advising on will structures for subsequent marriages.

5.2 Historical Deaths Under Estate Duty and Capital Transfer Tax

For first deaths before 13 March 1975 (Estate Duty) or between 13 March 1975 and 17 March 1986 (Capital Transfer Tax), HMRC guidance at IHTM43060 establishes the "nil rate" equivalent as the amount below which no duty or tax was payable.24 Historical spouse exemption limits must be factored into the calculation:

  • Before 22 March 1972: no spouse or charitable exemption existed under Estate Duty
  • 22 March 1972 to 12 November 1974: spouse exemption limited to GBP 15,000
  • From 13 November 1974: unlimited spouse exemption for UK-domiciled spouses24

These historical limits have a direct impact on the TNRB calculation. Where the first death occurred before 22 March 1972, the absence of a spouse exemption means that assets passing to the surviving spouse were potentially chargeable, reducing the transferable percentage. Accountants handling such estates must reconstruct the historical tax position using the prevailing rate tables and exemption thresholds. HMRC's historical rate tables, while not always easily accessible, are essential reference material for these calculations.

6. The Residence-Based IHT Regime and TNRB

The Finance Act 2025 replaced domicile with long-term UK residence (LTUR) as the IHT connecting factor from 6 April 2025.3 An individual is now subject to UK IHT on worldwide assets if they have been UK tax resident for at least 10 of the 20 tax years preceding the chargeable event.

6.1 Impact on TNRB Calculations

For a first spouse who was not a long-term UK resident (or, for deaths before 6 April 2025, was not UK domiciled), HMRC guidance at IHTM43042 confirms that the transferable NRB is calculated by reference to UK-situs property only.25 The VT in the TNRB formula is based on property potentially subject to UK IHT charge, not the deceased's worldwide estate.

This can produce a counterintuitive result: a higher transferable percentage. If the first spouse had substantial overseas assets (not subject to UK IHT) but modest UK assets, the UK-situs estate may have used little or none of the NRB, leaving a large percentage -- potentially 100% -- available for transfer. Accountants should identify cases where non-UK resident first spouses had minimal UK-situs assets, as these may yield full or near-full TNRB claims.

6.2 The Non-Long-Term-Resident Spouse Exemption Limit

Where a UK long-term resident transfers assets to a spouse who is not a long-term UK resident, the spouse exemption under IHTA 1984 s.18(2) is limited to the NRB (currently GBP 325,000) rather than being unlimited.26 This restricted exemption interacts with TNRB planning: the GBP 325,000 limit on lifetime spousal transfers consumes capacity that might otherwise have been available on death. Practitioners advising couples with mixed residence status must model the interaction between the restricted spouse exemption, the TNRB percentage calculation, and the overall estate planning position.

6.3 Transitional Considerations

Deaths straddling the 6 April 2025 implementation date require careful analysis. For first deaths before 6 April 2025, the former domicile-based rules determine whether the deceased was subject to UK IHT on worldwide assets. For survivor deaths on or after 6 April 2025, the residence-based regime applies to the survivor's own estate. The TNRB calculation for the first death, however, references the rules in force at the date of the first death -- meaning that domicile remains relevant for determining VT where the first spouse died before April 2025.325

7. Legacy NRB Discretionary Trusts

7.1 Constituted Versus Unconstituted Trusts

Many wills drafted before 9 October 2007 contain NRB discretionary trust provisions directing assets equal to the NRB into trust on first death, with the residue passing to the surviving spouse. HMRC acknowledges at IHTM43016 that in many cases the trust was never properly constituted -- frequently because the only substantial asset was a half share of the matrimonial home held under a joint tenancy that was never severed.27

The distinction has direct consequences for TNRB availability:

Where the trust was not constituted:

  • The full spouse exemption applied on the first death
  • The full NRB remains unused and available for transfer via TNRB
  • The result is economically identical to a simple survivorship will

Where the trust was constituted:

  • The NRB was used on the first death
  • No TNRB (or a reduced amount) is available for transfer
  • The trust assets are subject to the relevant property regime, including 10-yearly charges at up to 6%

HMRC requires case-by-case determination of whether the trust was constituted. Accountants should examine the original will, the grant of probate, and any post-death administration records to establish whether assets were actually appropriated to the trust. Where the only asset was a jointly-held property that passed by survivorship, the trust was almost certainly not constituted.27

7.2 RNRB Interaction with Legacy Trusts

If a qualifying residential interest is held in a discretionary trust, the residence nil-rate band is not available because the property is not "closely inherited" by a direct descendant on death, unless an appointment is made under IHTA 1984 s.144 within two years of death.28 Legacy NRB discretionary trusts that hold the former matrimonial home can therefore defeat both TNRB and RNRB if not managed correctly. Where such trusts are identified, practitioners should consider whether the trust terms permit an appointment to a direct descendant, or whether a deed of variation under IHTA 1984 s.142 (if within the two-year window) could redirect assets to secure RNRB eligibility.29

7.3 Practical Assessment Framework

Accountants encountering pre-2007 wills with NRB discretionary trust provisions should adopt a structured assessment:

  1. Establish whether the trust was constituted -- Review the grant of probate, estate accounts, and any trust accounts or tax returns
  2. Identify the trust assets -- Determine whether property was severed from a joint tenancy and whether other assets were appropriated
  3. Assess ongoing trust obligations -- Constituted trusts require 10-yearly returns and potential exit charges
  4. Calculate the TNRB position -- If unconstituted, the full NRB is available for transfer; if constituted, calculate the remaining percentage
  5. Evaluate RNRB implications -- If the trust holds a residential interest, assess whether a s.144 appointment could secure RNRB

8. Forward-Looking Context: Pension Inclusion and APR/BPR Allowance

8.1 Pension Death Benefits from April 2027

Unused defined contribution pension funds and pension death benefits will be included in the estate value for IHT purposes from 6 April 2027.4 While this measure has confirmed policy status with draft legislation published, final enactment remains subject to parliamentary process. The cascading effect on NRB planning is significant:

  • Pension values count toward the GBP 2 million RNRB taper threshold, potentially triggering withdrawal of the RNRB at GBP 1 for every GBP 2 above GBP 2 million
  • The NRB and TNRB apply before the RNRB in the IHT calculation; maximising TNRB claims is therefore essential to reduce the taxable estate before the RNRB taper is assessed
  • The spousal exemption applies to pension death benefits paid to a surviving spouse, so strategic pension nomination remains relevant as a planning tool

For an estate with GBP 1.8 million in non-pension assets and GBP 400,000 in pension funds, the total estate of GBP 2.2 million would exceed the RNRB taper threshold by GBP 200,000, reducing the available RNRB by GBP 100,000 (from GBP 175,000 to GBP 75,000). A successful TNRB claim doubling the NRB to GBP 650,000 would shelter more of the estate from the charge, though it does not directly affect the taper calculation. In 2022-23, 30,600 estates claimed RNRB, sheltering GBP 7.72 billion of estate value -- a figure that pension inclusion will place under pressure for many estates.30

8.2 APR/BPR Allowance from April 2026

From 6 April 2026, 100% agricultural property relief and business property relief will be capped at GBP 2.5 million per individual (raised from the originally proposed GBP 1 million following the 23 December 2025 announcement), with 50% relief applying above that threshold.9 The GBP 2.5 million allowance is transferable between spouses on the same percentage-based model as the NRB. This creates a new dimension for estate planning: accountants must now coordinate three separate transferable allowances -- NRB, RNRB, and APR/BPR -- between spouses, each with its own percentage-based transfer mechanism and procedural requirements.

The interaction demands integrated modelling. For an estate containing agricultural property valued at GBP 3 million alongside non-agricultural assets, the combined effect of NRB, TNRB, RNRB (if a qualifying residential interest passes to a direct descendant), and APR allowance (potentially GBP 5 million if fully transferred between spouses) requires coordinated analysis. Practitioners should develop comprehensive estate planning models that capture the interaction of all three transferable allowances and their respective taper thresholds.

Conclusion

The transferable nil-rate band under IHTA 1984 ss.8A-8C is both a foundational IHT relief and an area of persistent technical complexity. The percentage-based calculation to four decimal places, the procedural time limits, and the myriad complications arising from historical deaths, multiple marriages, legacy trust structures, and the new residence-based IHT regime all demand rigorous analytical discipline from practitioners.

Three developments make mastery of TNRB mechanics more urgent in 2026 and beyond. The residence-based IHT regime from April 2025 has altered the calculation for estates involving non-UK resident first spouses, potentially increasing transferable percentages in ways that were not available under the former domicile-based system.25 Pension death benefit inclusion from April 2027 will push more estates above the RNRB taper threshold, amplifying the value of every percentage point of TNRB claimed.4 And the APR/BPR allowance transferability from April 2026 introduces a third transferable allowance that must be coordinated alongside NRB and RNRB in integrated estate planning models.9

Accountants who invest in understanding the technical nuances of TNRB -- from reconstructing historical tax positions for pre-1975 deaths to assessing whether legacy NRB discretionary trusts were constituted -- will deliver tangible financial benefits to the estates they administer and the families they advise. As IHT receipts trend toward record levels and the NRB freeze continues through 2029-30, the margin between correct and incorrect TNRB claims carries increasing financial significance.

CPD Declaration

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

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Calculate the transferable nil-rate band percentage using the E / NRBMD x 100 formula for estates involving lifetime transfers and partial NRB usage on first death
  2. Identify the procedural requirements and time limits for TNRB claims via forms IHT402 and IHT217, including documentation obligations for historical first deaths
  3. Evaluate whether a legacy NRB discretionary trust was properly constituted and assess its impact on TNRB availability using the framework at IHTM43016
  4. Apply the residence-based IHT regime (from 6 April 2025) to TNRB calculations where the first spouse was not a long-term UK resident under IHTM43042
  5. Analyse the interaction between TNRB, pension death benefit inclusion (April 2027), and the RNRB taper threshold to determine the combined effect on estate tax liability

Competency Mapping

  • ICAEW Code of Ethics: Professional Competence and Due Care (Section 130) -- maintaining current knowledge of IHT legislation and HMRC practice
  • ATT/CTA Professional Standards: Technical competence in inheritance tax advisory work, accurate computation, and regulatory compliance

Reflective Questions

  1. How would the identification of an unconstituted NRB discretionary trust in a pre-2007 will change the TNRB calculation for estates currently under administration?
  2. What additional due diligence steps should be implemented when advising on TNRB claims for estates where the first spouse was not a long-term UK resident?
  3. How might the inclusion of pension death benefits in the IHT net from April 2027 affect current estate planning recommendations for clients with significant defined contribution pension wealth?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-24. 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 and NICs Receipts Monthly Bulletin (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. Finance Act 2025, Part 3 -- Inheritance Tax. https://www.legislation.gov.uk/ukpga/2025/8/part/3/crossheading/inheritance-tax ↩

  3. Finance Act 2025, Part 2, Chapter 4 -- Residence-Based IHT Regime. https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩ ↩2 ↩3 ↩4

  4. 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 ↩ ↩2 ↩3 ↩4

  5. GOV.UK -- NRB and RNRB Thresholds from 6 April 2026. https://www.gov.uk/government/publications/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026-to-5-april-2028 ↩

  6. House of Commons Library -- Inheritance Tax: A Basic Guide. https://commonslibrary.parliament.uk/research-briefings/sn00573/ ↩

  7. HMRC IHT Liabilities Statistics Commentary (2022-23). https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩

  8. OBR -- Inheritance Tax Forecasts. https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  9. GOV.UK -- APR and BPR Changes (23 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

  10. IHTA 1984, s.8A -- Transferable Nil-Rate Band. https://www.legislation.gov.uk/ukpga/1984/51/section/8A ↩ ↩2 ↩3

  11. Finance Act 2008, s.10, Schedule 4. https://www.legislation.gov.uk/ukpga/2008/9 ↩

  12. IHTM43001 -- Basic Principles: Introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43001 ↩

  13. IHTM43020 -- Calculating the Transferable NRB. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43020 ↩ ↩2 ↩3

  14. IHTM43030 -- Multiple Spouses. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43030 ↩ ↩2 ↩3

  15. IHTA 1984, s.8B -- Claims Procedure. https://www.legislation.gov.uk/ukpga/1984/51/section/8B ↩

  16. IHTM43021 -- Calculation with Lifetime Transfers. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43021 ↩ ↩2

  17. IHTM43034 -- CLTs by Second Spouse. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43034 ↩

  18. GOV.UK -- IHT402 Form and Guidance. https://www.gov.uk/government/publications/inheritance-tax-claim-to-transfer-unused-nil-rate-band-iht402 ↩

  19. GOV.UK -- IHT217 Form for Excepted Estates. https://www.gov.uk/government/publications/inheritance-tax-claim-to-transfer-unused-nil-rate-band-for-excepted-estates-iht217 ↩

  20. IHTM06024 -- Excepted Estates and TNRB. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm06024 ↩

  21. IHTM43007 -- Time Limits. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43007 ↩

  22. IHTM43009 -- Late Claims. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43009 ↩

  23. IHTM43006 -- How to Make a Claim. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43006 ↩

  24. IHTM43060 -- Estate Duty and Capital Transfer Tax. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43060 ↩ ↩2

  25. IHTM43042 -- Domicile/LTUR and TNRB. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43042 ↩ ↩2 ↩3

  26. IHTM11033 -- Spouse Exemption (Non-UK Domiciled/LTUR). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm11033 ↩

  27. IHTM43016 -- Unconstituted NRB Trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43016 ↩ ↩2

  28. IHTM46033 -- RNRB: Inherited Condition and Settled Property. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46033 ↩

  29. IHTA 1984, s.142 -- Deeds of Variation. https://www.legislation.gov.uk/ukpga/1984/51/section/142 ↩

  30. HMRC IHT Liabilities Statistics -- RNRB Claims 2022-23. https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩

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