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M&A Employee Benefits Integration: Estate Planning Considerations in Business Combinations

· 21 min

Executive Summary

Employee benefits integration in mergers and acquisitions addresses pension alignment, healthcare consolidation, and compensation harmonisation -- yet systematically neglects estate planning, exposing acquirers and transferring employees to material tax and legal risk. Three developments make this omission unsustainable. From 6 April 2027, most unused pension funds and pension death benefits enter inheritance tax scope, though death-in-service benefits from registered pension schemes remain excluded.1 TUPE Regulation 10 excludes occupational pension rights relating to old age, invalidity, and survivors from automatic transfer protections, creating a gap where employees may lose estate-efficient pension structures during business transfers.2 Post-merger benefits harmonisation decisions directly affect the IHT efficiency of employer-provided death benefits for the combined workforce. With UK M&A deal value reaching USD 181.3 billion in 2025 and 70% of transactions failing to achieve intended value, benefits integration managers face a compelling case for incorporating estate planning into M&A due diligence and harmonisation processes.34

1. The Missing Dimension in M&A Benefits Integration

UK mergers and acquisitions activity remained robust in 2025, with deal value reaching USD 181.3 billion -- slightly above the prior year.3 The first half of 2025 recorded 1,478 transactions with a total deal value of GBP 57.3 billion and an average deal size of GBP 169.2 million, reflecting a 63% increase in average transaction size despite a 19.1% decline in volume.3 Activity concentrated in technology, financial services, and real estate, with 2026 forecasts cautiously optimistic as stabilising interest rates and substantial private equity dry powder are expected to sustain deal flow.5

The people dimension of these transactions is well documented -- and persistently problematic. Approximately 70% of M&A transactions fail to achieve intended value, with people integration and cultural challenges cited as primary factors.4 Research from the Cass Business School M&A Research Centre found that 93% of executives believe post-deal organisational challenges could be prevented through early HR involvement in the transaction process.6 Benefits integration is a core component of this early engagement, yet the scope of benefits due diligence and harmonisation frameworks remains incomplete.

Standard M&A benefits integration addresses pension scheme alignment, healthcare plan consolidation, bonus and incentive harmonisation, and contractual benefit compliance under TUPE.7 Estate planning is absent. No major HR publication, benefits advisory firm, or M&A integration framework addresses how transaction structure, pension arrangements, death benefit design, and post-merger harmonisation decisions affect the estate planning position of transferring employees. This absence was defensible when pension death benefits sat outside the inheritance tax system. It is no longer defensible.

From 6 April 2027, most unused pension funds and pension death benefits will be included in the deceased's estate for IHT purposes.1 The government's consultation response, published in July 2025, confirmed that personal representatives -- not pension scheme administrators -- will be liable for reporting and paying IHT on covered pension assets.8 Death-in-service benefits from registered pension schemes remain excluded from IHT scope, regardless of whether the scheme operates on a discretionary or non-discretionary basis.1 This distinction -- between pension death benefits now within IHT scope and death-in-service benefits that remain outside it -- transforms the benefits integration landscape. The structure of the target company's death benefit arrangements becomes a due diligence variable with direct tax consequences for transferring employees and, by extension, for the acquirer's post-completion benefits strategy.

The Aon UK Benefits and Trends Survey 2025, covering more than 240 employers, found that 94% of organisations agree that employers have a responsibility for influencing employee health and wellbeing, with 41% maintaining a formalised health and wellbeing strategy.9 Estate planning support during M&A transitions aligns with this evolving employer responsibility, particularly where benefits harmonisation decisions alter the IHT profile of death benefits for the combined workforce.

2. Transaction Structure and Benefits Implications

2.1 Share Sales: Continuity with Inherited Risk

The distinction between share sales and asset sales is fundamental to the benefits integration analysis in business combinations, because it determines whether TUPE applies and, consequently, the regulatory framework governing employee benefits transition from one employer to another.10

In a share sale, the target company's legal identity is unchanged -- only ownership of its share capital transfers to the acquirer. TUPE generally does not apply because the employer entity remains the same; employees continue on identical contractual terms with the same employer.10 Pension schemes, group life policies, private medical insurance, group income protection, and all other benefits continue without interruption. The acquirer inherits all liabilities associated with these arrangements, including pension scheme deficits, section 75 employer debts, and any outstanding employee claims.

From an estate planning perspective, a share sale preserves the status quo. Employees' existing pension death benefit structures -- including any excepted group life policies operating as discretionary trusts under ITTOIA 2005 ss.481-482 -- remain intact.11 The employer/settlor of any trust-based death benefit arrangement is unchanged, because the employing entity has not changed. However, the acquirer may seek to harmonise benefits post-completion, at which point estate planning considerations become directly relevant.

2.2 Asset Sales and Business Transfers: The TUPE Framework

In an asset sale or business transfer, TUPE applies where the transfer constitutes a "relevant transfer" -- a business or part of a business moves as a going concern to a new employer.1012 Employees automatically transfer to the transferee on their existing terms and conditions. The transferee cannot vary contractual terms where the sole or principal reason is the transfer itself; variations are permitted only for "economic, technical or organisational" (ETO) reasons entailing changes in the workforce.12

Insured benefits -- group life insurance, private medical insurance, and group income protection -- transfer as contractual rights where they form part of the employment contract.1314 The transferee must arrange replacement cover from Day One, matching the contractual terms of the transferor's arrangements. Failure to do so constitutes a breach of contract.

The Employment Rights Act 2025 (c.36), which received Royal Assent on 18 December 2025, increases the stakes for compliance in business combination HR. From April 2026, the maximum protective award for failure to comply with collective redundancy consultation obligations under TULRCA 1992 s.189 increases from 90 days' to 180 days' pay per employee.1516 This increase applies to collective redundancy consultation, not to the separate TUPE Regulation 15 information and consultation obligation, which retains its existing enforcement framework under TUPE Regulation 16 (compensation of up to 13 weeks' pay per employee).217 However, M&A transactions frequently involve both TUPE transfers and redundancy programmes, making both consultation regimes relevant to the same transaction. The government has also issued a call for evidence on TUPE-related issues, signalling potential further reform.16

2.3 Estate Planning Divergence: A Comparative Scenario

Consider two structurally identical transactions involving the same target company -- a mid-market technology firm with 250 employees, an excepted group life policy providing four times salary death-in-service cover under a discretionary trust, and a defined contribution occupational pension scheme.

Scenario A (Share sale): The acquirer purchases 100% of the target's share capital. The employing entity is unchanged. The excepted group life policy trust remains intact with the original employer as settlor. The DC occupational pension scheme continues on existing terms. Employees' estate planning position is unaffected by the transaction itself, though the acquirer may later harmonise benefits.

Scenario B (Asset sale): The acquirer purchases the target's business and assets. TUPE applies. Employees transfer on existing contractual terms, but Regulation 10 excludes occupational pension rights relating to old age, invalidity, and survivors.2 The transferee is required to provide minimum pension provision under the Transfer of Employment (Pension Protection) Regulations 2005 -- matched contributions up to 6% of pensionable salary -- but is not obliged to replicate the transferor's occupational pension scheme.18 The excepted group life policy presents a separate challenge: the employer/settlor has changed, potentially disrupting the trust arrangement and its IHT efficiency.11 The transferee must either establish equivalent trust arrangements satisfying ITTOIA 2005 ss.481-482 or risk the death benefit falling within the employee's estate for IHT purposes from April 2027.

This divergence -- identical target, identical employees, different transaction structure, materially different estate planning outcomes -- illustrates why benefits integration managers must understand the structural implications of the deal they are integrating.

3. TUPE, Pensions, and the Regulatory Framework

3.1 Regulation 10: The Pension Exclusion

Regulation 10 of the Transfer of Undertakings (Protection of Employment) Regulations 2006 provides that the automatic transfer provisions (Regulations 4 and 5) "shall not apply to so much of a contract of employment or collective agreement as relates to an occupational pension scheme" within the meaning of section 1 of the Pension Schemes Act 1993.2 The exclusion applies only to benefits relating to old age, invalidity, or survivors. Regulation 10(2) clarifies that provisions of an occupational pension scheme not relating to those categories are treated as outside the pension scheme definition for TUPE purposes and therefore do transfer.2

The practical implications for benefits integration are precise. First, occupational pension rights relating to retirement, invalidity, and death benefits do not automatically transfer to the new employer in an asset sale or business transfer. Second, the exclusion applies only to occupational pension schemes as defined by PSA 1993 s.1 -- group personal pension schemes and stakeholder pension arrangements are not excluded from TUPE transfer and must be maintained on existing terms.19 Third, the transferee is not required to replicate the transferor's occupational pension scheme, merely to meet the minimum provision requirements under separate regulations.

3.2 Minimum Pension Protections Post-Transfer

The Transfer of Employment (Pension Protection) Regulations 2005 (SI 2005/649), made under section 258 of the Pensions Act 2004, establish a minimum pension provision floor for transferring employees who were members of (or eligible to join) an occupational pension scheme immediately before the transfer.1820 The transferee must provide either matched employer contributions up to 6% of pensionable salary for a defined contribution arrangement, or comparable defined benefit provision, or access to a stakeholder pension with matched contributions up to 6%.18 Where the transferring employee contributed less than 6% before the transfer, the transferee is required to match only that lower amount, following the April 2014 amendment.18

This minimum provision represents a floor, not a ceiling. The gap between the transferor's scheme (which might offer employer contributions of 10% or more, plus comprehensive death-in-service benefits within the pension scheme) and the 6% matched-contribution minimum can be substantial. For benefits integration managers, the pension provision gap is a well-understood risk. The estate planning dimension of this gap -- the potential loss of estate-efficient death benefit structures associated with the transferor's occupational pension scheme -- is the consideration that existing integration frameworks overlook.

3.3 Beckmann and Martin Rights: The Nuanced Boundary

Two European Court of Justice decisions established that pension-linked benefits not relating to "old age, invalidity or survivors" transfer under TUPE despite the Regulation 10 exclusion. Beckmann v Dynamco Whicheloe Macfarlane Ltd (Case C-164/00, 2002) held that early retirement benefits payable on redundancy are not "old age benefits" and therefore transfer under the Acquired Rights Directive.21 Martin v South Bank University (Case C-4/01, 2003) extended this principle to early retirement benefits arising by employer-employee agreement.21 Procter & Gamble (2012) confirmed that Beckmann/Martin principles apply to private sector schemes, while clarifying that only certain enhancements -- not full early retirement benefits -- transfer.21

These "Beckmann rights" represent a material due diligence consideration. The transferee may inherit early retirement enhancement obligations carrying significant financial exposure. Benefits integration managers should ensure that legal and pensions due diligence identifies any Beckmann liabilities within the target's pension arrangements, as these obligations transfer irrespective of the Regulation 10 exclusion.

4. Pension Death Benefits, Death-in-Service, and the April 2027 IHT Changes

4.1 The April 2027 Reform

From 6 April 2027, most unused pension funds and pension death benefits will be included in the deceased's estate for IHT purposes.1 The government's policy framework, confirmed through the consultation response published on 21 July 2025, establishes the following distinctions relevant to employer-provided benefits.8

Death-in-service benefits payable from registered pension schemes are excluded from IHT scope, regardless of whether the scheme is discretionary or non-discretionary.1 This exclusion applies equally to lump sum death benefits and dependant's scheme pensions from defined benefit and collective money purchase arrangements.1 Other pension death benefits -- including defined contribution lump sums from accumulated pension pots and drawdown funds -- enter IHT scope.1 Personal representatives are liable for reporting and paying IHT; they may direct scheme administrators to withhold up to 50% of benefits for up to 15 months to cover potential IHT liabilities.8 Existing spousal and charitable exemptions are maintained.8

The government's impact assessment estimates that approximately 10,500 estates will acquire new IHT liability and 38,500 estates will pay more IHT as a result, with an average additional liability of approximately GBP 34,000 per affected estate.1 IHT receipts reached GBP 7.1 billion in the period April 2025 to January 2026, with the nil-rate band frozen at GBP 325,000 and the residence nil-rate band at GBP 175,000, both extended to April 2030-31.2223

4.2 Implications for M&A Due Diligence

The April 2027 changes create new due diligence requirements that benefits integration managers must incorporate into pre-transaction planning.

Death benefit structure audit. The acquirer's due diligence team should identify whether the target company's death-in-service benefits are provided through a registered pension scheme (excluded from IHT from April 2027), through an excepted group life policy operating as a discretionary trust (outside the employee's estate under existing IHT rules), or through other arrangements that may fall within IHT scope.111 The structure of the benefit -- not merely its quantum -- is now material to the estate planning position of the target's workforce.

Excepted group life policy review. Excepted group life policies satisfying ITTOIA 2005 ss.481-482 criteria operate as discretionary trusts with the employer as settlor.1124 Benefits are payable only to an employee's family or dependants if the employee dies in service before retirement age, with trustees exercising discretion over beneficiary selection and payment proportions. Because trustees have discretion over payment, benefits are not treated as within the deceased member's estate for IHT purposes.11 Where a business transfer occurs, the employer/settlor changes. The transferee must establish equivalent trust arrangements or risk the policy failing the statutory conditions -- a failure that could bring death benefits within the employee's estate for IHT purposes.

DC pension accumulation. Employees with significant defined contribution pension accumulations in the target's scheme face new IHT exposure from April 2027. Harmonisation decisions -- such as consolidating pension schemes post-merger -- must account for the IHT treatment of accumulated pension funds, particularly where the target's scheme offered features (such as death-in-service lump sums payable from the pension scheme) that the acquirer's scheme does not replicate.

The interaction of these considerations with diversity and inclusion in benefits design warrants attention. Employees in diverse family structures -- including cohabiting partners, civil partners, and blended families -- may be affected differently by changes to death benefit structures and nomination processes during M&A transitions. Benefits integration managers should ensure that harmonised death benefit arrangements and expression-of-wish processes are inclusive and accommodate the range of family circumstances within the combined workforce.

4.3 Defined Benefit Pension Schemes: Existing Complexity Compounded

Defined benefit pension schemes in M&A transactions present established financial risks that the estate planning dimension compounds but does not replace. Section 75 of the Pensions Act 1995 (as substituted by section 271 of the Pensions Act 2004) imposes a debt on an employer of a DB pension scheme where certain trigger events occur, including an employer ceasing to participate in a multi-employer scheme or a scheme winding up.2526 The debt is calculated on a buy-out basis -- the cost of securing members' benefits with an insurance company -- which typically exceeds the ongoing funding basis deficit substantially.

The Pensions Regulator holds anti-avoidance powers under the Pensions Act 2004 to issue contribution notices requiring payment of specified sums to the pension scheme and financial support directions requiring connected entities to provide financial support.27 These powers can pierce the corporate veil, reaching group companies, controlling shareholders, and individual directors. The voluntary clearance procedure enables parties to M&A transactions involving DB pension schemes to obtain a statement from TPR confirming that it will not exercise these powers in relation to a specified transaction.27

For benefits integration managers, the section 75 and TPR clearance framework remains the dominant pension concern in M&A. Estate planning considerations -- specifically, the IHT treatment of DB scheme death benefits (dependant's scheme pensions from DB arrangements are excluded from IHT from April 2027) and the implications of scheme restructuring for death benefit entitlements -- represent an additional layer within this established risk framework.1

5. Practical Framework for Estate-Aware Benefits Integration

5.1 Pre-Transaction Due Diligence

Estate-aware benefits due diligence extends the standard checklist with the following considerations.

Death benefit structure mapping. Classify the target's death benefit arrangements into three categories: (a) death-in-service benefits from registered pension schemes (excluded from IHT from April 2027); (b) excepted group life policies under ITTOIA 2005 ss.481-482 (outside the employee's estate under existing IHT rules, subject to trust arrangement integrity); and (c) other death benefit arrangements (potentially within IHT scope from April 2027).111 This classification determines the estate planning exposure that the transaction creates or preserves.

Trust arrangement review. For excepted group life policies, verify the trust documentation, identify the employer/settlor, and assess whether the transaction structure (share sale or asset sale) will disrupt the trust arrangement. In an asset sale, legal advice should confirm whether the transferee automatically assumes the settlor role or whether a new trust must be established to maintain ITTOIA 2005 compliance.1124

Beckmann rights assessment. Identify any early retirement enhancement obligations that transfer under Beckmann/Martin principles, independent of the Regulation 10 exclusion. These liabilities have financial and, in some cases, estate planning implications where they interact with death benefit entitlements.21

Section 75 and TPR clearance. For transactions involving DB pension schemes, assess section 75 exposure and determine whether TPR clearance is appropriate. Integrate this assessment with the death benefit structure review, particularly where DB scheme restructuring might alter dependant's pension entitlements.2527

5.2 Day One Readiness

Day One readiness for estate-aware benefits integration requires the following.

Death-in-service continuity. Ensure that death-in-service cover is in place from the transfer date. In an asset sale, the transferee must arrange replacement cover matching the contractual terms of the transferor's arrangements. Where the transferor provided death-in-service benefits through an excepted group life policy, the transferee should maintain the existing trust arrangements pending a full harmonisation review rather than immediately restructuring into a standard group life scheme.

Expression-of-wish forms. Transferring employees should be invited to review and update expression-of-wish forms (or death benefit nomination forms) with the new pension scheme or death benefit arrangement as soon as administratively practicable. This is particularly important where the transaction changes the death benefit provider, trustee, or scheme administrator.

Employee communication. Benefits statements issued during the TUPE consultation period should clearly describe the death benefit arrangements that will be in place from Day One, including any changes from the transferor's arrangements. Where the transaction structure means that occupational pension death benefits will not transfer (due to Regulation 10), transparent communication about the replacement arrangements and their implications is essential.

5.3 Post-Completion Harmonisation

Post-completion benefits harmonisation is where estate planning considerations have their greatest practical impact. Benefits integration managers typically face three harmonisation options: harmonise up (adopt the more generous package across the combined entity), harmonise down (adopt the less generous package), or redesign (create a new unified package).7 Each option has estate planning implications.

Harmonise up. If the acquirer's death benefit structure is less estate-efficient than the target's -- for example, if the acquirer provides standard group life insurance without an excepted group life policy trust arrangement -- harmonising up to include estate-efficient structures for the combined workforce strengthens the overall benefits proposition. This approach aligns with the Aon finding that 94% of organisations accept responsibility for employee wellbeing.9

Harmonise down. If harmonisation involves replacing the target's excepted group life policy with the acquirer's standard group life arrangement, the estate planning position of transferring employees may deteriorate. Death benefits that were previously outside the employee's estate (paid at trustee discretion under the excepted group life policy) may move into IHT scope. Benefits integration managers should quantify this impact and communicate it to affected employees.

Redesign. A comprehensive redesign offers the opportunity to incorporate estate planning as a design variable alongside cost, competitiveness, and compliance. Best practice, as articulated by benefits advisers, requires like-for-like comparison, phased implementation, employee engagement, and clear communication throughout the harmonisation process.7 Adding estate planning to this framework means assessing the IHT efficiency of each design option before committing to a harmonised structure.

Phased implementation is particularly valuable in the estate planning context. Immediate conversion of death benefit structures creates unnecessary risk where the IHT implications have not been fully assessed. A phased approach allows the benefits integration team to complete the IHT analysis, obtain specialist tax and pension advice, and communicate changes to employees before implementing structural changes to death benefit arrangements.

Conclusion

The inclusion of most pension death benefits in IHT scope from April 2027 transforms estate planning from a peripheral concern into a core variable in M&A employee benefits integration. The structure of the target company's death benefit arrangements -- whether provided through registered pension scheme death-in-service benefits (excluded from IHT), excepted group life policies under discretionary trust (outside the estate), or other pension death benefits (within IHT scope) -- has direct and quantifiable tax consequences for transferring employees.

Transaction structure determines the regulatory framework: share sales preserve existing benefit arrangements, while asset sales trigger TUPE's Regulation 10 pension exclusion, potentially removing employees from estate-efficient occupational pension structures with only minimum protections under the 2005 Pension Protection Regulations. Post-merger harmonisation decisions amplify or mitigate these effects, making the harmonise-up, harmonise-down, or redesign choice an estate planning decision as well as a cost and competitiveness decision.

For benefits integration managers, the practical response is to add estate planning to the existing M&A playbook -- not to replace the established considerations of cost, compliance, retention, and cultural integration, but to ensure that death benefit structures are assessed for IHT efficiency alongside these traditional factors. With the collective redundancy protective award increasing to 180 days' pay from April 2026 -- raising the cost of non-compliance in M&A transactions involving redundancy programmes -- and with pension IHT rules taking effect from April 2027, the regulatory environment surrounding business combinations is tightening. The window for incorporating estate planning into M&A benefits integration frameworks is narrowing. The guidance in this area remains limited, but the regulatory trajectory is clear.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: M&A Benefits Integration, Employee Benefits, Pension and Death Benefit Planning, TUPE Compliance

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Distinguish between share sales and asset sales in terms of TUPE applicability and the consequent impact on employee benefit structure continuity, including estate planning implications
  2. Identify how TUPE Regulation 10's occupational pension exclusion interacts with the Transfer of Employment (Pension Protection) Regulations 2005 to create a benefits gap for transferring employees
  3. Evaluate the impact of the April 2027 pension death benefit IHT changes on M&A due diligence requirements, particularly the distinction between excluded death-in-service benefits and other pension death benefits entering IHT scope
  4. Apply a structured due diligence and harmonisation checklist that incorporates estate planning considerations alongside traditional benefits integration factors
  5. Assess the IHT implications of benefits harmonisation decisions for excepted group life policies and death-in-service benefit structures

Competency Mapping

  • CIPD Associate Level: Benefits Design and Management -- applying technical knowledge of benefit structures to organisational change scenarios
  • CIPD Associate Level: People Practice -- managing employee transitions during business combinations with awareness of regulatory requirements
  • CIPD Advanced Level: Reward Strategy -- integrating tax efficiency considerations into benefits harmonisation decisions during M&A

Reflective Questions

  1. How would the distinction between share sales and asset sales affect the benefits integration approach in a transaction currently under consideration within your organisation?
  2. What additional due diligence steps would you implement to assess the IHT profile of a target company's death benefit arrangements in light of the April 2027 pension changes?
  3. How might your current benefits harmonisation framework be adapted to incorporate estate planning as a design variable alongside cost, competitiveness, and compliance?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 26 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. 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 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  2. Transfer of Undertakings (Protection of Employment) Regulations 2006 (SI 2006/246), Regulation 10. https://www.legislation.gov.uk/uksi/2006/246/regulation/10 ↩ ↩2 ↩3 ↩4 ↩5

  3. PwC, UK M&A activity contracts in H1 2025, but strategic investment drives resilience in deal value. https://www.pwc.co.uk/press-room/press-releases/research-commentary/2024/uk-m-a-activity-contracts-in-h1-2025--but-strategic-investment-d.html ↩ ↩2 ↩3

  4. McKinsey & Company, M&A Insights / Merger Management Compendium. https://www.mckinsey.com/capabilities/m-and-a/our-insights ↩ ↩2

  5. Wedlake Bell, UK private M&A trends: insights from 2025 and predictions for 2026. https://wedlakebell.com/insights/uk-private-ma-trends-insights-from-2025-and-predictions-for-2026/ ↩

  6. Employee Benefits / Cass Business School M&A Research Centre, Dr Valeriya Vitkova: HR involvement is key in mergers and acquisition deals. https://employeebenefits.co.uk/dr-valeriya-vitkova-hr-involvement-is-key-in-mergers-and-acquisition-deals/148240.article ↩

  7. Lockton, M&A best practice: harmonising employee benefits. https://global.lockton.com/gb/en/news-insights/m-and-a-best-practice-harmonising-employee-benefits ↩ ↩2 ↩3

  8. GOV.UK, Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses. https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩ ↩2 ↩3 ↩4

  9. Aon, UK Benefits and Trends Survey 2025. https://www.aon.com/en-gb/capabilities/health-and-benefits/uk-benefits-and-trends-survey ↩ ↩2

  10. GOV.UK, Business transfers, takeovers and TUPE. https://www.gov.uk/transfers-takeovers ↩ ↩2 ↩3

  11. HMRC Inheritance Tax Manual, IHTM17091 -- Pensions: excepted group life policies: introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm17091 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  12. Acas, TUPE transfers. https://www.acas.org.uk/tupe-transfers ↩ ↩2

  13. Transfer of Undertakings (Protection of Employment) Regulations 2006 (SI 2006/246), Regulation 4. https://www.legislation.gov.uk/uksi/2006/246/regulation/4 ↩

  14. Drewberry, TUPE Transfers and Employee Benefits Guide. https://www.drewberryinsurance.co.uk/employee-benefits/guides/tupe-transfers-and-employee-benefits ↩

  15. Employment Rights Act 2025 (c.36). https://www.legislation.gov.uk/ukpga/2025/36/contents/enacted ↩

  16. Pinsent Masons, Employment Rights Act: implementation for UK employers in 2026 and beyond. https://www.pinsentmasons.com/out-law/guides/employment-rights-bill-timeline-2026-beyond ↩ ↩2

  17. Transfer of Undertakings (Protection of Employment) Regulations 2006 (SI 2006/246), Regulation 16. https://www.legislation.gov.uk/uksi/2006/246/regulation/16 ↩

  18. Transfer of Employment (Pension Protection) Regulations 2005 (SI 2005/649). https://www.legislation.gov.uk/uksi/2005/649/contents ↩ ↩2 ↩3 ↩4

  19. Gowling WLG, TUPE and pensions -- back to basics. https://gowlingwlg.com/en/insights-resources/articles/2017/tupe-and-pensions-back-to-basics ↩

  20. House of Commons Library, TUPE and Pensions (SN01665). https://commonslibrary.parliament.uk/research-briefings/sn01665/ ↩

  21. Gowling WLG, Beckmann rights: back to basics. https://gowlingwlg.com/en/insights-resources/articles/2019/beckmann-rights-back-to-basics ↩ ↩2 ↩3 ↩4

  22. HMRC Tax Receipts and National Insurance Contributions for the UK (monthly bulletin). 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 ↩

  23. GOV.UK, Inheritance Tax Thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  24. HMRC Insurance Policyholder Taxation Manual, IPTM7030 -- Exceptions: group life policies: conditions about permitted benefits: ITTOIA05/S481. https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm7030 ↩ ↩2

  25. Pensions Act 1995, section 75 (as substituted by Pensions Act 2004, s.271). https://www.legislation.gov.uk/ukpga/1995/26/section/75 ↩ ↩2

  26. House of Commons Library, Section 75 employer debt and multi-employer pension schemes (CBP-7684). https://commonslibrary.parliament.uk/research-briefings/CBP-7684/ ↩

  27. The Pensions Regulator, Clearance. https://www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/communications-and-reporting-detailed-guidance/clearance ↩ ↩2 ↩3

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