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ISA Inheritance and Estate Planning: Additional Permitted Subscriptions Explained

· 21 min

Executive Summary

The UK Individual Savings Account market holds GBP 872 billion across approximately 15 million accounts, yet Additional Permitted Subscriptions (APS) remain one of the most underutilised estate planning tools available to surviving spouses and civil partners. Since 3 December 2014, bereaved individuals can inherit their deceased partner's ISA tax advantages through APS, enabling substantial one-time subscriptions beyond the standard GBP 20,000 annual limit. The April 2018 continuing ISA reforms introduced the higher-of-two-values calculation, creating strategic timing opportunities during estate administration. With the April 2026 reduction of AIM share business property relief from 100% to 50%, and the new residence-based IHT regime operational since April 2025, advisers must understand APS mechanics to optimise client outcomes. This article provides advanced technical guidance on valuation strategies, provider selection implications, and integration with broader estate planning frameworks.

1. Introduction: The ISA Inheritance Landscape

When an ISA holder dies, a common misconception persists that the tax-advantaged wrapper simply disappears. In reality, the legislative framework provides multiple mechanisms for preserving and transferring ISA benefits, yet anecdotal reports from advisers and provider surveys suggest many surviving spouses do not fully utilise their APS entitlements, often due to lack of awareness or the complexity of the application process.1

The scale of the planning opportunity is substantial. HMRC's Annual Savings Statistics for 2025 reveal that the total Adult ISA market reached GBP 872 billion by the end of the 2023-24 tax year, representing a 20.1% increase year-on-year.2 This growth trajectory reflects both increased subscription activity and investment performance within existing accounts. The statistics reveal that approximately 15 million Adult ISA accounts received subscriptions during the 2023-24 tax year, up from 12.4 million the previous year.3

Critically, the average ISA holding for investors aged 65 and over stands at GBP 64,386, meaning bereaved spouses of older investors frequently face APS entitlements several times larger than the standard annual ISA allowance of GBP 20,000.4 For couples who have accumulated ISA wealth over multiple decades since the introduction of Personal Equity Plans in 1987 and their ISA successors in 1999, combined holdings can exceed GBP 500,000, representing potential APS entitlements equivalent to 25 years of standard subscriptions.

The regulatory framework for ISA inheritance has evolved significantly. The Individual Savings Account Regulations 1998 (SI 1998/1870) received material amendments through the Individual Savings Account (Amendment No. 2) Regulations 2015, which introduced APS for deaths on or after 3 December 2014.5 This reform responded to the perceived inequity that surviving spouses lost access to their deceased partner's tax-advantaged savings capacity, despite the couple having built that capacity together during marriage or civil partnership.

Subsequent amendments through SI 2017/1089 established the continuing account rules for deaths on or after 6 April 2018, fundamentally changing both the tax treatment during estate administration and the calculation methodology for APS entitlements.6 These reforms recognised that the immediate cessation of ISA wrapper benefits upon death could disadvantage estates where administration took significant time, particularly for complex portfolios or contentious probate situations.

For financial advisers, understanding these mechanisms serves multiple purposes: delivering genuine value to bereaved clients during difficult circumstances, creating referral opportunities from solicitors handling estate administration, and demonstrating technical competence that differentiates advisory services in a competitive market. The combination of technical complexity and emotional sensitivity surrounding bereavement creates an environment where professional guidance delivers tangible benefits.

2. The ISA Inheritance Framework

2.1 Pre-April 2018 Deaths: The Original APS Regime

For account holders who died between 3 December 2014 and 5 April 2018, the APS entitlement equals the value of ISA holdings at the date of death. The ISA wrapper ceased immediately upon death, meaning any subsequent investment growth accrued outside the tax-advantaged environment.7

Under this original regime, investment income and capital gains arising after death became taxable within the estate. For estates taking significant time to administer, potentially years in complex cases, this exposure could prove material. The cessation also meant that personal representatives faced decisions about whether to liquidate investments or hold them pending distribution, knowing that ongoing returns would generate tax liabilities.

The surviving spouse or civil partner receives a one-time additional subscription allowance matching the death-date value. This allowance operates independently from the standard annual ISA subscription limit, enabling significant capital to be sheltered from future income tax and capital gains tax. The independence of APS from annual limits means a surviving spouse could, in theory, subscribe their full APS entitlement in a single tax year while also using their standard GBP 20,000 allowance for separate savings.

2.2 Post-April 2018 Deaths: The Continuing ISA Account

The Individual Savings Account (Amendment No. 3) Regulations 2017 transformed the landscape for deaths occurring on or after 6 April 2018 by introducing the "continuing account of a deceased investor" concept.8

Upon the account holder's death, the ISA does not lose its tax-advantaged status immediately. Instead, it becomes a continuing ISA with the following characteristics:

Tax Treatment During Continuation:

  • No Income Tax liability on interest, dividends, or distributions
  • No Capital Gains Tax on disposals within the account
  • The account maintains its ISA wrapper protections

This continuation preserves substantial value in estates holding significant ISA assets. Consider a portfolio generating GBP 15,000 annual dividends within the ISA wrapper: without continuing account status, a two-year administration period could generate GBP 30,000 of taxable dividend income, potentially exceeding the dividend allowance and creating higher-rate tax liabilities.

Management Permissions:

  • Existing investments may be actively managed
  • Switches between funds within the ISA are permitted
  • No new subscriptions allowed to the continuing account

The active management permission proves particularly valuable for continuing ISAs containing concentrated positions or sector-specific holdings that require rebalancing during volatile market conditions. Personal representatives can instruct switches without triggering capital gains tax, enabling prudent portfolio management during estate administration.

Cessation Triggers: The continuing ISA ceases being a continuing account on the earliest of three events: completion of estate administration, closure of the ISA by the personal representatives, or three years and one day after the date of death.9 If the three-year limit expires before closure, the ISA wrapper is removed, and the investments become subject to standard tax treatment from that date.

The three-year limit creates a hard deadline that advisers must monitor carefully. Complex estates involving property, business interests, or family disputes may approach this threshold, requiring proactive decisions about ISA closure timing to preserve optimal APS calculations.

2.3 The Higher-of-Two-Values Calculation

For deaths on or after 6 April 2018, the APS entitlement equals the higher of:

  1. The value of ISA holdings at the date of death, OR
  2. The value immediately before the ISA ceases to be a continuing account

This creates a meaningful strategic dimension. If markets rise during the estate administration period, delaying the closure of continuing ISAs (within the three-year limit) can increase the surviving spouse's APS entitlement. Conversely, if markets decline, the death-date value provides a floor.10

The asymmetric protection this provides is substantial. The surviving spouse gains access to upside participation without downside exposure to the APS calculation, though the estate itself remains exposed to investment risk on the underlying assets.

Worked Example:

Consider a deceased ISA holder with GBP 150,000 in stocks and shares ISAs at the date of death (1 March 2025). If the portfolio grows to GBP 175,000 by the time the estate is administered (1 September 2025), the surviving spouse receives APS of GBP 175,000, not the death-date value.

At the current GBP 20,000 annual limit (frozen until April 2031), this represents approximately 8.75 years of standard ISA subscriptions available as a single entitlement.11

Conversely, if markets decline and the portfolio falls to GBP 130,000 by administration completion, the APS entitlement remains GBP 150,000 based on the death-date value. The estate realises the loss, but the surviving spouse's sheltering capacity is preserved.

Strategic Timing Considerations:

Advisers assisting with estate administration should monitor continuing ISA valuations regularly, particularly when approaching estate completion. Where values have appreciated above death-date levels, the timing of ISA closure becomes a strategic decision. However, several constraints apply:

  • The ISA cannot be artificially kept open solely for APS optimisation; administration completion triggers closure
  • Market volatility creates uncertainty about optimal timing
  • The three-year absolute deadline prevents indefinite deferral
  • Other estate beneficiaries may have conflicting interests regarding asset retention

3. Additional Permitted Subscriptions: Technical Requirements

3.1 Eligibility Criteria

APS availability is restricted to the deceased's spouse or civil partner, subject to the following conditions:

  • The couple must have been legally married or in a civil partnership at the time of death
  • They must have been living together at the date of death (not separated under a court order or deed of separation)
  • The survivor need not be UK resident (subject to ISA manager acceptance)12

The "living together" requirement excludes couples who had formally separated, though temporary absences for work, medical treatment, or other non-separation reasons do not disqualify the survivor. HMRC guidance does not provide exhaustive definitions, creating potential ambiguity in borderline cases.

Notably, cohabiting partners without marriage or civil partnership cannot access APS regardless of relationship duration, creating a significant planning distinction that advisers should communicate to unmarried clients with substantial ISA holdings. This represents one of several tax and estate planning advantages that marriage or civil partnership confers, potentially influencing lifetime planning decisions for long-term cohabiting couples.

3.2 Time Limits and Deadlines

The permitted period for APS subscriptions varies between cash and in-specie transfers:

Cash Subscriptions: The later of:

  • Three years from the date of death, OR
  • 180 days after completion of estate administration

This dual-limb structure provides flexibility. Where estate administration completes quickly (within approximately two years and six months of death), the three-year anniversary provides the deadline. Where administration extends beyond that point, the 180-day buffer from completion preserves reasonable time for APS arrangements.

In-Specie Transfers:

  • 180 days from the date beneficial ownership of the ISA investments transfers to the surviving spouse13

The stricter deadline for in-specie transfers reflects the operational complexity of transferring underlying investments. Advisers should note that in-specie transfers typically take approximately three times longer than cash transfers to execute, making early engagement with ISA managers essential.

The 180-day in-specie deadline runs from beneficial ownership transfer, not from death or administration completion. Where ISA assets pass to the surviving spouse through residuary estate distribution, the trigger date is when beneficial ownership actually transfers, which may lag behind grant of probate by weeks or months depending on estate complexity.

3.3 Documentation Requirements

ISA managers require specific documentation before accepting APS applications:

  • Death certificate or interim death certificate
  • Marriage or civil partnership certificate
  • Completed APS application form (manager-specific)
  • For in-specie transfers: evidence of beneficial ownership transfer

Managers may provisionally accept applications pending full documentation, with a 30-day correction window for incomplete submissions.14 This provisional acceptance mechanism enables APS to proceed while families obtain official documents that may take time to acquire, particularly where registrar delays affect death certificate issuance.

3.4 Valuation and Calculation

The APS limit equals the combined value of all deceased's ISAs at the relevant date(s). Where multiple ISAs exist with different managers:

  • Each ISA's value contributes to the total APS entitlement
  • The survivor may elect either death-date or closure-date valuation
  • However, the chosen approach must be applied consistently across all managers; mixing approaches is not permitted15

The consistency requirement means survivors cannot cherry-pick death-date values for ISAs that have fallen and closure-date values for ISAs that have risen. The election must be all-or-nothing across the deceased's entire ISA portfolio.

For continuing ISAs, the value includes any dividends or distributions received between the ex-date and payment date at the time of closure, which accretes to the APS allowance. This technical detail can add meaningful sums where the deceased held high-dividend portfolios and closure occurs shortly after ex-dates for major distributions.

4. Provider Selection and the Lock-In Mechanism

4.1 The Permanent Provider Commitment

Perhaps the most significant operational constraint advisers must communicate concerns provider selection. Once partial APS is used with any provider, a permanent lock-in applies:

  • Only that provider can receive subsequent APS top-up subscriptions
  • Transferring an ISA containing APS-funded subscriptions results in forfeiture of any unused APS entitlement
  • Future contributions to that ISA are limited to the standard GBP 20,000 annual allowance if transferred16

This constraint survives the 2024 ISA Amendment Regulations (SI 2024/350), which otherwise permit multiple ISAs of the same type within a single tax year.17 The reforms enabling ISA flexibility did not extend to relaxing the APS provider lock-in rule.

The permanence of this commitment cannot be overstated. A surviving spouse with GBP 200,000 APS entitlement who subscribes GBP 50,000 with Provider A in year one cannot subsequently switch to Provider B for the remaining GBP 150,000. The choice of provider in that first subscription determines where all subsequent APS must flow. If the client transfers the ISA to Provider B, the unused GBP 150,000 APS entitlement is forfeit entirely.

4.2 Provider Selection Framework

Given the permanent nature of the provider commitment, advisers should apply rigorous due diligence criteria:

Investment Range:

  • Does the provider offer the full range of investments the client may require (funds, shares, bonds, AIM securities)?
  • Are there restrictions on asset classes or minimum holding sizes?
  • Does the platform provide access to offshore funds, investment trusts, or other specialist vehicles?

Cost Structure:

  • Platform fees, dealing charges, and fund access costs
  • Exit fees that could penalise future transfers of non-APS holdings
  • Foreign exchange charges for non-GBP investments
  • Fees for corporate actions or dividend reinvestment

Service Quality:

  • Track record with APS applications
  • Processing times for in-specie transfers
  • Quality of bereavement administration services
  • Availability of dedicated technical support

Future Flexibility:

  • LISA availability (relevant for eligible clients under 40)
  • Junior ISA options if relevant to family circumstances
  • Ability to hold alternative investments should regulations expand ISA-qualifying assets

4.3 Manager Discretion

ISA managers are not obligated to accept APS applications. While most mainstream providers do accept APS, some platforms have operational limitations or policy restrictions. Advisers should confirm acceptance before initiating applications, particularly for:

  • Non-UK resident applicants
  • In-specie transfers of complex assets (illiquid funds, physical shares with paper certificates)
  • Applications close to time limit deadlines
  • Large APS amounts that may require enhanced due diligence

The discretionary nature of acceptance creates execution risk. Advisers should not assume that any provider will accept APS merely because competitors do, and should obtain written confirmation of acceptance terms before recommending provider selection to clients.

5. Strategic Integration with Estate Planning

5.1 APS and Inheritance Tax: A Critical Distinction

A fundamental point that advisers must communicate clearly: APS preserves income tax and capital gains tax advantages, not inheritance tax exemptions. The value of the deceased's ISAs forms part of the estate for IHT purposes, subject to:

  • The nil-rate band (frozen at GBP 325,000 until April 2031)
  • The residence nil-rate band (GBP 175,000, subject to taper)
  • The spouse exemption (if passing to surviving spouse)18

The APS mechanism does not create additional IHT shelter; it enables the surviving spouse to maintain tax-efficient wrapper treatment on assets that would otherwise become taxable investments.

Where ISA assets pass to the surviving spouse under the spousal exemption, no immediate IHT arises. However, those assets then form part of the surviving spouse's estate, potentially increasing their own IHT exposure on second death. The APS mechanism does not affect this calculation but does preserve the ongoing income and CGT advantages during the survivor's lifetime.

This distinction between ISA treatment and other asset classes remains important as the legislative landscape evolves. From April 2027, pension death benefits will become subject to IHT under new income tax rules, representing a significant shift in estate planning strategy for clients with substantial pension wealth.19 ISAs, by contrast, have always been within the IHT net, making APS a mechanism for preserving income and CGT efficiency rather than IHT mitigation.

5.2 AIM ISA Strategies Post-April 2026

The Autumn Budget 2024 confirmed that business property relief for AIM shares reduces from 100% to 50% from 6 April 2026.20 This materially affects post-inheritance planning for clients considering AIM investments within ISAs.

Pre-April 2026 Position:

  • AIM shares held for two or more years at death qualify for 100% BPR
  • The ISA value is effectively exempt from IHT if invested in qualifying AIM securities
  • Combining ISA and BPR creates dual tax advantages (income/CGT and IHT)

Post-April 2026 Position:

  • Same qualifying AIM shares attract only 50% BPR
  • GBP 200,000 in AIM ISA attracts BPR of GBP 100,000, leaving GBP 100,000 exposed to IHT at 40% (GBP 40,000 tax)
  • The cost-benefit calculation changes significantly

For clients inheriting ISAs via APS in 2026 and beyond, the decision to deploy inherited capital into AIM requires revised analysis. The income and CGT advantages of the ISA wrapper remain, but the IHT efficiency is halved. Advisers should model scenarios comparing AIM ISA holdings against alternative IHT mitigation strategies, including whole-of-life insurance, gifts from income, and trust-based planning.21

The two-year qualifying period for BPR also creates timing considerations. AIM investments made using APS in year one do not attract any BPR until year three, during which period the investor bears full AIM market risk without IHT mitigation. This risk-return profile has deteriorated materially with the 50% reduction.

5.3 Lifetime ISA Integration

Where a Lifetime ISA forms part of the deceased's holdings, specific rules apply:

  • The government bonus element is included in the APS calculation
  • Funds withdrawn from the deceased's LISA exit the LISA wrapper (no 25% withdrawal penalty)
  • The surviving spouse can contribute up to GBP 4,000 per year of their APS entitlement into their own LISA if eligible (under 40, first-time buyer status)22

This creates potential planning opportunities for younger surviving spouses who have not yet purchased a first home or who wish to supplement retirement savings with LISA benefits. The government bonus of 25% on LISA contributions makes this an attractive deployment option where eligibility criteria are met.

5.4 Cross-Border Considerations

APS is available to non-UK resident surviving spouses, subject to ISA manager discretion.23 However, several complexities arise:

New Subscriptions vs APS: While APS does not require UK residence, opening new ISAs generally requires UK tax residence. A non-UK resident spouse may claim APS into an existing UK ISA but cannot subsequently make standard annual subscriptions until regaining UK residence.

Residence-Based IHT Regime: The residence-based IHT regime, enacted from 6 April 2025, replaced the previous domicile-based system. Under the new framework, individuals become long-term UK residents for IHT purposes after 10 years of UK residence (20 years for non-doms arriving before 6 April 2025), with tail provisions of three to ten years after departure.24

For internationally mobile clients, the intersection of ISA inheritance, APS entitlements, and the new residence-based IHT regime requires coordinated planning. Non-UK resident surviving spouses with UK ISA holdings may face different IHT treatment depending on their own residence history and that of the deceased. The combination of UK-situs assets (ISA investments) and potentially excluded property for IHT purposes creates technical complexity warranting specialist advice.

6. Practical Implementation for Advisers

6.1 Client Identification and Engagement

Proactive identification of APS opportunities requires systematic processes:

New Client Onboarding:

  • Include spousal ISA holdings in standard fact-find documentation
  • Note ISA manager details to facilitate future APS applications
  • Discuss APS during lifetime planning conversations

Existing Client Reviews:

  • Maintain records of client spousal bereavements
  • Cross-reference with known ISA holdings
  • Initiate APS conversations within appropriate timeframes

Referral Network Development:

  • Establish relationships with solicitors handling probate
  • Provide technical briefings on APS to referral partners
  • Offer joint client meetings during estate administration

6.2 The APS Application Process

A structured approach ensures optimal outcomes:

Phase 1: Information Gathering (Weeks 1-4)

  • Obtain ISA valuations at date of death from all managers
  • Confirm continuing ISA status (deaths on/after 6 April 2018)
  • Calculate total APS entitlement across all holdings

Phase 2: Strategy Development (Weeks 4-8)

  • Assess higher-of-two-values opportunities
  • Evaluate provider options against lock-in implications
  • Determine cash vs in-specie preference
  • Integrate with broader estate and IHT planning

Phase 3: Execution (Timing Variable)

  • Submit applications with required documentation
  • Monitor continuing ISA values for optimisation opportunities
  • Coordinate with estate administration timeline
  • Confirm successful subscription before deadline expiry

6.3 Common Pitfalls and Risk Mitigation

Missed Deadlines: The 180-day limit for in-specie transfers can catch advisers and clients unaware, particularly where estate administration extends. Calendar management systems should flag approaching deadlines with sufficient lead time for execution.

Premature Provider Selection: Clients sometimes apply to their own ISA provider without considering alternatives. The permanent lock-in makes reversing this decision impossible.

Valuation Timing Errors: Failing to monitor continuing ISA values may forfeit higher-of-two-values benefits. Regular valuation reviews during estate administration are advisable.

Documentation Gaps: Incomplete applications consume the 30-day correction window. Advisers should assemble full documentation before submission.

6.4 Compliance Considerations

While APS administration does not itself constitute regulated financial advice, associated recommendations may engage regulatory requirements:

  • Investment recommendations for deploying APS funds require appropriate permissions
  • Cash vs in-specie decisions involve investment considerations
  • AIM ISA recommendations carry additional risk disclosures
  • Suitability assessments apply to ongoing investment advice

Advisers should document the boundary between administrative assistance and regulated advice, particularly where bereavement circumstances may affect client vulnerability assessments under Consumer Duty requirements.

Conclusion

Additional Permitted Subscriptions represent a significant but frequently underexploited mechanism for preserving tax-advantaged treatment on inherited ISA wealth. The combination of generous time limits, the higher-of-two-values calculation, and flexibility for non-UK residents creates genuine planning value for bereaved clients with ISA-holding spouses.

However, the permanent provider lock-in, differential deadlines for cash and in-specie transfers, and the need to integrate APS with broader estate planning considerations demand technical precision from advising professionals. The April 2026 reduction in AIM share business property relief adds further complexity for clients considering post-inheritance IHT planning strategies.

Future developments warrant continued monitoring, including the April 2027 changes to pension death benefit taxation which will shift client focus toward alternative tax-advantaged structures such as ISAs and APS for surviving spouses.

Advisers who develop systematic processes for identifying APS opportunities, maintain current technical knowledge of ISA inheritance rules, and establish effective referral relationships with estate administration professionals will deliver tangible value to clients during periods of significant need. The GBP 872 billion UK ISA market ensures that APS opportunities will remain substantial for the foreseeable future, warranting continued professional development in this technical area.

CPD Declaration

Estimated Reading Time: 22 minutes Technical Level: Advanced Practice Areas: Estate Planning, Tax-Efficient Investing, Bereavement Services, Wealth Management

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Distinguish between the ISA inheritance rules applicable to pre-April 2018 and post-April 2018 deaths, including the continuing ISA account provisions and their tax treatment implications
  2. Calculate Additional Permitted Subscription entitlements using the higher-of-two-values methodology and apply strategic timing considerations during estate administration
  3. Evaluate provider selection decisions in light of the permanent APS lock-in mechanism and its implications for long-term client outcomes
  4. Analyse the interaction between APS, the April 2026 AIM share BPR reduction, and the residence-based IHT regime when advising internationally mobile or IHT-conscious clients

SRA Competency Mapping

  • Technical Legal Practice: Estate planning and tax-efficient structures
  • Client Care: Serving vulnerable and bereaved clients appropriately
  • Risk Management: Deadline compliance and documentation standards

FCA Competency Mapping

  • T&C 2.1: Technical Knowledge and Skills (investment wrappers, tax treatment)
  • COBS 9: Suitability (integrating APS with investment recommendations)

Reflective Questions

  1. How would current practice processes identify clients with APS entitlements arising from recent spousal bereavements, and what improvements might enhance capture rates?
  2. What provider selection criteria would apply when advising a client with a GBP 200,000 APS entitlement who wishes to consider AIM investments alongside mainstream equities?
  3. How does the April 2026 business property relief reduction affect the advice provided to clients inheriting ISA portfolios who previously planned to utilise AIM ISA strategies for IHT mitigation?

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.

Footnotes

Footnotes

  1. Royal London for Advisers, "ISA Rules on Death and Additional Permitted Subscriptions" (noting complexity as barrier to uptake). https://adviser.royallondon.com/technical-central/isa/isa-death-and-additional-permitted-subscriptions/ ↩

  2. HMRC Annual Savings Statistics: September 2025 Commentary. https://www.gov.uk/government/statistics/annual-savings-statistics-2025/commentary-for-annual-savings-statistics-september-2025 ↩

  3. HMRC Annual Savings Statistics: September 2025 Commentary (subscription accounts data). https://www.gov.uk/government/statistics/annual-savings-statistics-2025/commentary-for-annual-savings-statistics-september-2025 ↩

  4. HMRC Annual Savings Statistics: September 2025 Commentary (average holdings by age). https://www.gov.uk/government/statistics/annual-savings-statistics-2025/commentary-for-annual-savings-statistics-september-2025 ↩

  5. The Individual Savings Account Regulations 1998, Regulation 5DDA (as inserted by SI 2015/869). https://www.legislation.gov.uk/uksi/1998/1870/regulation/5DDA ↩

  6. The Individual Savings Account (Amendment No. 3) Regulations 2017, SI 2017/1089. https://www.legislation.gov.uk/uksi/2017/1089/made ↩

  7. GOV.UK, "Individual Savings Accounts (ISAs): If you die." https://www.gov.uk/individual-savings-accounts/if-you-die ↩

  8. The Individual Savings Account (Amendment No. 3) Regulations 2017, SI 2017/1089, Regulation 4. https://www.legislation.gov.uk/uksi/2017/1089/made ↩

  9. GOV.UK, "Individual Savings Accounts (ISAs): Inheriting an ISA from your spouse or civil partner." https://www.gov.uk/individual-savings-accounts/inheriting-an-isa-from-your-spouse-civil-partner ↩

  10. Royal London for Advisers, "ISA Rules on Death and Additional Permitted Subscriptions." https://adviser.royallondon.com/technical-central/isa/isa-death-and-additional-permitted-subscriptions/ ↩

  11. HMRC Tax-free savings newsletter 19, November 2025. https://www.gov.uk/government/publications/tax-free-savings-newsletter-19/tax-free-savings-newsletter-19-november-2025 ↩

  12. GOV.UK, "How to manage additional permitted subscriptions into an ISA." https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa ↩

  13. GOV.UK, "How to manage additional permitted subscriptions into an ISA" (time limits). https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa ↩

  14. GOV.UK, "How to manage additional permitted subscriptions into an ISA" (documentation). https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa ↩

  15. Aberdeen Adviser TechZone, "Applying for the ISA APS." https://techzone.aberdeenadviser.com/public/investment/Practical-guide-App-for-ISAAPS ↩

  16. Aberdeen Adviser TechZone, "Applying for the ISA APS" (provider lock-in). https://techzone.aberdeenadviser.com/public/investment/Practical-guide-App-for-ISAAPS ↩

  17. The Individual Savings Account (Amendment) Regulations 2024, SI 2024/350. https://www.legislation.gov.uk/uksi/2024/350/made ↩

  18. GOV.UK, "How Inheritance Tax works: thresholds, rules and allowances." https://www.gov.uk/inheritance-tax ↩

  19. GOV.UK, "Inheritance Tax: unused pension funds and death benefits" (pension death benefits from April 2027). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  20. HM Treasury, "Summary of reforms to agricultural property relief and business property relief." https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩

  21. Downing Adviser Hub, "Additional Permitted Subscriptions (APS) for ISAs." https://www.downing.co.uk/education-hub-resources/additional-permitted-subscriptions-aps-for-isas ↩

  22. GOV.UK, "Managing a Lifetime ISA when an investor dies or is terminally ill." https://www.gov.uk/guidance/managing-a-lifetime-isa-when-an-investor-dies-or-is-terminally-ill ↩

  23. GOV.UK, "How to manage additional permitted subscriptions into an ISA" (non-UK residents). https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa ↩

  24. GOV.UK, "Inheritance Tax if you're a long-term UK resident" (residence-based regime). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩

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