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Pensions and Estate Planning: Death Benefit Tax Rules and Nomination Strategy

· 20 min

Executive Summary

The Finance (No.2) Bill 2025-26, which had its first reading on 2 December 2025 and entered Public Bill Committee on 27 January 2026, will bring most unused pension funds and death benefits within the inheritance tax estate for deaths on or after 6 April 2027. This change dismantles the long-standing assumption that pensions represent an optimal intergenerational wealth transfer vehicle outside the IHT net. The government estimates 10,500 estates will acquire new IHT liability, with an average increase of approximately GBP 34,000 per affected estate. For post-age-75 deaths, combined effective tax rates exceeding 64% create acute double taxation risk. Personal representatives -- not scheme administrators -- will bear IHT reporting and payment liability, following the reversal of the original consultation proposal. Advisers face a 14-month implementation window to audit client nominations, recalibrate decumulation strategies, and integrate these changes with the residence-based IHT regime operational from April 2025.

1. Introduction: The April 2027 Watershed

The Autumn Budget 2024, delivered on 30 October 2024, announced one of the most consequential changes to the taxation of pension wealth in a generation: the inclusion of most unused pension funds and death benefits within the scope of IHT.1 Following a technical consultation that ran from 30 October 2024 to 22 January 2025 -- attracting 649 written responses and nine industry workshops -- the government published its consultation outcome and revised policy paper on 21 July 2025.2 The Finance (No.2) Bill 2025-26 received its first reading on 2 December 2025, embedding the pension IHT provisions in draft legislation. The Bill passed second reading on 16 December 2025, Committee of the Whole House on 12-13 January 2026, and entered Public Bill Committee on 27 January 2026, with proceedings expected to conclude by 26 February 2026.3

The scale of fiscal impact is significant. Revenue estimates project GBP 640 million in 2027/28, rising to GBP 1.34 billion in 2028/29 and GBP 1.46 billion by 2029/30.3 HMRC's own Tax Information and Impact Note estimates that 10,500 estates will face a new IHT liability, with a further 38,500 estates paying more IHT, at an average increase of approximately GBP 34,000 per affected estate.4

For advisory practices, the implications are threefold. First, the decumulation hierarchy -- the long-established principle of spending non-pension assets first while preserving pension wealth for intergenerational transfer -- requires fundamental reassessment. Second, nomination forms and trustee discretion serve a different purpose in a post-2027 environment. Third, the interaction between this change and the residence-based IHT regime, operational from 6 April 2025, creates layered complexity for internationally mobile clients.5 This article provides an integrated framework addressing each dimension, with worked tax calculations and a practical nomination strategy hierarchy for adviser implementation.

2. Current Income Tax Framework for Pension Death Benefits

Before examining the IHT overlay, a precise understanding of the existing income tax treatment of pension death benefits is essential. The age-75 threshold remains the primary determinant of income tax liability on death benefits from defined contribution arrangements. This framework -- established by the pension flexibility reforms of 2015 and modified by the lifetime allowance abolition from April 2024 -- forms the baseline against which the April 2027 IHT inclusion must be assessed.

Pre-Age-75 Deaths

Where the member dies before age 75, lump sum death benefits paid from unused funds are generally free of income tax, provided two conditions are met: payment occurs within two years of the scheme administrator becoming aware of the death, and the total does not exceed the Lump Sum and Death Benefit Allowance (LSDBA) of GBP 1,073,100.6 The LSDBA replaced the lifetime allowance from 6 April 2024 under provisions in Schedule 9 of the Finance Act 2024.7 Any excess above the LSDBA is taxed at the recipient's marginal income tax rate.

A critical planning distinction arises here. Beneficiary drawdown -- where the pension fund is designated into a drawdown arrangement for the beneficiary rather than paid as a lump sum -- is not tested against the LSDBA.8 This means that for pre-75 deaths where the deceased's LSDBA is partially or fully exhausted by other lump sums (such as a pension commencement lump sum taken during lifetime), designating death benefits into beneficiary drawdown preserves the income tax advantage that would otherwise be lost on a lump sum payment exceeding the allowance. For a member who took a GBP 268,275 tax-free lump sum during lifetime, the remaining LSDBA stands at GBP 804,825 -- a lump sum death benefit exceeding that amount would be partially taxable, whereas beneficiary drawdown avoids this constraint entirely.

Post-Age-75 Deaths

For deaths at or after age 75, all pension death benefits -- whether paid as lump sums or through beneficiary drawdown -- are taxable at the recipient's marginal income tax rate.9 Where benefits are paid to a trust rather than to an individual, a special charge at 45% applies. The two-year rule does not affect the taxability of post-75 death benefits; they are taxable regardless of payment timing, though the two-year window remains relevant for scheme administration purposes.

The distinction between lump sum and drawdown delivery remains important even for post-75 deaths. A lump sum payment crystallises the full income tax liability in a single tax year, potentially pushing the recipient into higher rate bands. Drawdown payments, by contrast, can be spread across multiple tax years, enabling the beneficiary to manage marginal rate exposure through the timing and quantum of withdrawals. For a GBP 500,000 fund, a lump sum to an additional rate taxpayer produces a GBP 225,000 income tax charge in a single year, whereas drawdown over ten years at GBP 50,000 annually could reduce the effective rate significantly depending on the beneficiary's other income.

3. The IHT Inclusion: Scope, Exemptions, and Mechanics

Benefits Within Scope

From 6 April 2027, for deaths on or after that date, the following categories of pension death benefit will fall within the value of the deceased's estate for IHT purposes: unused DC pension funds (including SIPPs and SSASs), unused drawdown pension funds, lump sum death benefits from DC arrangements, death in deferment lump sums from DB schemes, five-year guarantee payments from DB schemes, and benefits from qualifying non-UK pension schemes and section 615(3) schemes.10

Exclusions

The legislation excludes several categories. Death in service benefits -- payable where an active scheme member dies during employment -- remain outside the IHT estate. Dependants' scheme pensions from DB or collective money purchase arrangements are similarly excluded. Benefits passing to a surviving spouse or civil partner benefit from the standard spousal IHT exemption, while charity lump sum death benefits attract charitable exemption.11

The exclusion of death in service benefits and dependants' DB pensions reflects the policy rationale that these benefits represent income replacement rather than wealth accumulation. The distinction matters for advisory practice: a client with both DC and DB entitlements will have differing IHT exposures across their pension arrangements. A former employee with a deferred DB pension and a separate SIPP may find that the DB dependant's pension passes IHT-free while the SIPP fund is fully within the IHT estate.

Liability: Personal Representatives, Not Scheme Administrators

The original consultation proposed that pension scheme administrators would bear IHT liability -- a position that attracted significant opposition from the pensions industry. Following the consultation, the government reversed this proposal. Personal representatives will be responsible for reporting and paying IHT on pension death benefits.12 This represents a fundamental shift in estate administration complexity. Personal representatives must now obtain valuations of pension assets from each scheme, integrate them with non-pension estate values, and allocate the nil-rate band proportionally across the combined estate. The valuation process itself introduces practical challenges: scheme administrators must provide valuations within a timeframe compatible with the six-month IHT reporting deadline, and multiple pension arrangements may complicate the aggregation exercise.

The 50% Withholding Mechanism

To address the practical challenge of IHT payment before pension benefits are distributed, the legislation introduces a withholding mechanism. Where personal representatives reasonably expect IHT to be due, they may issue a withholding notice to the pension scheme administrator, requiring the scheme to withhold up to 50% of taxable benefits for up to 15 months from the end of the month in which the individual died.13 Payments to a spouse, civil partner, or charity are excluded from the withholding.

Personal representatives or beneficiaries may instruct the scheme to pay IHT directly to HMRC, with the scheme required to remit within three weeks of receiving such instruction. The IHT reporting deadline remains within six months of the end of the month of death. This mechanism creates a potential liquidity constraint for beneficiaries expecting prompt access to pension death benefits; advisers should prepare clients and their families for delays of up to 15 months in benefit payment where IHT is anticipated.14

Nil-Rate Band Allocation

The nil-rate band (currently GBP 325,000) will be shared between pension and non-pension estate assets in proportion to their respective taxable values. No Business Relief is available for pension assets, including AIM portfolios held within pensions -- a point confirmed in the July 2025 policy paper that closes earlier speculation about BR eligibility for AIM holdings in self-invested pension arrangements.15

This proportional allocation means that the effective IHT rate on pension assets depends on the composition of the total estate. An estate comprising 70% pension wealth and 30% non-pension wealth will allocate 70% of the nil-rate band to pension assets and 30% to non-pension assets. Advisers should model this interaction when projecting IHT liability across different asset distribution scenarios.

4. Double Taxation: Quantifying the Impact

The most significant advisory concern arising from the April 2027 changes is double taxation: the application of both IHT (at 40%) and income tax (at up to 45%) to the same pension fund. For post-75 deaths, the combined effective rate can exceed 64%.16

Worked Example: Post-Age-75 Death (Married, Spouse Predeceased)

Consider a widowed member who dies at age 80 with a GBP 500,000 SIPP fund and a non-pension estate of GBP 500,000. The total estate is GBP 1,000,000. Assuming the nil-rate band (GBP 325,000), transferable nil-rate band (GBP 325,000 from the predeceased spouse), and residence nil-rate band (GBP 175,000) are available, the combined allowances total GBP 825,000. The taxable estate is GBP 175,000. IHT at 40% produces a liability of GBP 70,000.

Now consider a single member dying at age 80 with the same GBP 500,000 SIPP and GBP 500,000 non-pension estate. Available allowances are GBP 325,000 (NRB) plus GBP 175,000 (RNRB), totalling GBP 500,000. The taxable estate is GBP 500,000, and IHT at 40% produces GBP 200,000.

With proportional nil-rate band allocation for the single member, the pension share of the NRB is calculated as: (500,000 / 1,000,000) x 500,000 = 250,000. Approximately GBP 250,000 of allowances applies to the pension fund and GBP 250,000 to the non-pension estate. The IHT attributable to the pension is 40% of GBP 250,000 (being GBP 500,000 less GBP 250,000 allocated NRB), equalling GBP 100,000. The remaining pension fund of GBP 400,000 (after GBP 100,000 IHT) is then subject to income tax at the beneficiary's marginal rate. At 40% income tax, the further charge is GBP 160,000, leaving the beneficiary with GBP 240,000 from an original GBP 500,000 fund -- an effective combined rate of 52%.

Where the beneficiary is an additional rate taxpayer at 45%, the income tax charge on GBP 400,000 rises to GBP 180,000, leaving GBP 220,000 -- an effective rate of 56%. If the estate exceeds GBP 2 million and the RNRB tapers to nil, the effective rate climbs further, exceeding 64% in the most severe scenarios.17

Worked Example: Pre-Age-75 Death

By contrast, where death occurs before age 75, the income tax position is more favourable. A lump sum death benefit within the LSDBA is free of income tax, though subject to IHT from April 2027. On a GBP 500,000 fund where IHT is GBP 100,000 (per the allocation above), the beneficiary receives GBP 400,000 -- an effective rate of 20%. Beneficiary drawdown payments from a pre-75 death are not tested against the LSDBA and, where the death occurred before 75, each payment is tax-free. The IHT exposure remains, but the absence of income tax produces a materially lower effective rate.18

The Income Tax Reclaim Mechanism

The policy paper confirms that where income tax has been deducted on a relevant death benefit, the pension beneficiary may reclaim income tax on the amount of IHT paid in respect of the same benefit.19 This mechanism partially mitigates double taxation but does not eliminate it. The precise administrative process -- including the form, timeline, and procedural requirements -- is subject to further HMRC guidance expected before April 2027. Advisers should note that the reclaim applies only to the IHT element, not to the full income tax charge, and requires the beneficiary to take proactive steps that may not be intuitive to a bereaved family member unfamiliar with the tax system. Documenting the reclaim entitlement and the process for exercising it should form part of the post-death administration checklist that advisers prepare for client families.

5. Nomination Strategy in a Post-2027 Environment

The Shifting Rationale for Expression of Wish Forms

Prior to April 2027, the non-binding nature of expression of wish forms serves a dual purpose: directing the scheme trustees' discretion and -- critically -- keeping pension death benefits outside the IHT estate. HMRC's position, set out in IHTM17051, is that binding nominations create a "general power" to dispose of property, bringing benefits within the estate.20 Conversely, where trustees retain genuine discretion, benefits fall outside the estate.

From April 2027, this IHT planning rationale becomes irrelevant. Benefits will be within the estate regardless of whether nominations are binding or discretionary.21 However, expression of wish forms remain critically important for two reasons: they direct who receives benefits and they influence the form of benefit delivery (lump sum, drawdown, or annuity), which in turn drives the income tax outcome. Additionally, binding nominations -- previously avoided for IHT planning purposes -- may now be reconsidered where speed of payment is a priority, since trustees are not required to exercise discretion before making payment under a binding arrangement.

Advisers should note that individual nomination and decumulation recommendations to clients constitute regulated financial advice under the FCA framework and must be delivered within the suitability assessment process required by COBS 9.22

Nomination Hierarchy Post-2027

The spousal exemption becomes the primary planning lever. Benefits passing to a surviving spouse or civil partner remain exempt from IHT, making spousal nomination the default optimal position for married or civil-partnered clients.23 Charitable nominations similarly attract IHT exemption on the relevant portion, potentially also reducing the estate below the GBP 2 million RNRB taper threshold. Where a client's estate sits marginally above GBP 2 million, a charitable pension nomination of sufficient value to bring the estate below the threshold may preserve the full RNRB (GBP 175,000 or GBP 350,000 with transferable RNRB), producing a net IHT saving that exceeds the value of the charitable gift.

For non-exempt beneficiaries (adult children, for example), the choice between lump sum and drawdown nomination has material tax consequences. Drawdown preserves the ability to manage income tax exposure across multiple tax years, while a lump sum crystallises the full liability immediately. Advisers should document the rationale for nomination recommendations and ensure clients understand the income tax implications for each beneficiary category.

Spousal Bypass Trusts: A Fundamental Change

The treatment of spousal bypass trusts represents one of the most significant practical impacts of the April 2027 changes. Currently, lump sum death benefits paid to a bypass trust fall outside the deceased's estate where trustees exercise genuine discretion. From April 2027, lump sums paid to a bypass trust will be included in the deceased's estate for IHT.24 Existing bypass trust arrangements require urgent review. The spousal exemption applies only to benefits paid directly to the spouse or civil partner, not to a trust for their benefit. Advisers maintaining client files with spousal bypass trust nominations should prioritise these cases for review and potential restructuring.

Divorce and Outdated Nominations

A frequently overlooked advisory point: divorce does not revoke pension death benefit nominations. This stands in contrast to testamentary dispositions, where section 18A of the Wills Act 1837 (as inserted by the Administration of Justice Act 1982, s.18(2)) treats gifts to a former spouse as if the former spouse had predeceased on the date of dissolution.25 No equivalent statutory provision applies to pension nominations; the Wills Act 1837 governs only testamentary instruments and has no application to pension scheme nomination forms.26 A divorced client whose expression of wish form still names a former spouse risks benefits being directed -- and the associated IHT exemption being claimed -- on behalf of someone no longer intended as beneficiary. From April 2027, the interaction of outdated nominations with IHT liability adds further urgency to nomination audits for divorced and remarried clients.

6. Residence-Based IHT and Internationally Mobile Clients

The residence-based IHT regime, enacted from 6 April 2025, replaces the domicile-based system with a long-term UK resident test: an individual is within full IHT scope if resident in the UK for 10 out of the preceding 20 tax years.27 Tail provisions of 3 to 10 years (depending on length of prior UK residence) ensure that departing residents do not immediately escape IHT liability. This regime operates alongside the pension IHT inclusion from April 2027, creating a layered framework that affects internationally mobile clients with UK pension entitlements.

Interaction with Pension Death Benefits

For the majority of UK pension scheme members -- who will meet the long-term resident test -- the residence-based regime has no incremental effect on pension IHT liability. The interaction becomes material for two client categories.

First, expats with UK pension entitlements face continued IHT exposure during the tail period. A client who has been UK resident for 15 years and relocates abroad will remain within IHT scope for up to 10 years after departure. Any UK pension death benefits during that tail period will be within the IHT estate, potentially alongside the pension schemes of their new country of residence.28 This creates a dual-jurisdiction planning requirement that advisers should address in coordination with overseas tax specialists.

Second, non-long-term residents with UK pension assets present a more nuanced position. Where an individual does not meet the 10/20-year test and is outside the tail period, pension assets may fall outside IHT scope as excluded property, depending on situs analysis. However, the draft legislation extends the pension IHT charge to qualifying non-UK pension schemes (QNUPS) and qualifying recognised overseas pension schemes (QROPS), potentially capturing pension wealth that would otherwise be outside UK IHT.29

Advisers serving internationally mobile clients should model the interaction between long-term residence status, tail period duration, pension situs, and the QROPS/QNUPS rules when projecting post-2027 IHT exposure. The transitional rules for 2025/26 -- which require individuals who are neither UK resident nor UK-domiciled/deemed domiciled to meet the existing 15/20-year deemed domicile test -- add a further layer of complexity during the first year of the new regime.

7. Implementation Framework: A 14-Month Countdown

With the April 2027 effective date approximately 14 months away, advisory practices face a defined implementation window. The following framework segments the required actions by priority. Advisers should note that all individual client recommendations arising from this framework -- including nomination changes and decumulation adjustments -- constitute regulated advice under COBS 9 and must be delivered within the FCA suitability assessment process.22

Immediate Actions (Months 1-3)

Client segmentation by risk exposure is the first operational step. Clients with unused DC pension funds exceeding GBP 100,000 and total estates above the nil-rate band threshold should be flagged for priority review. Nomination audits should begin immediately, with particular attention to spousal bypass trust arrangements, outdated nominations following divorce, and cases where binding nominations were previously avoided for IHT reasons but may now be reconsidered for administrative efficiency.

Medium-Term Actions (Months 4-9)

Decumulation strategy review forms the core of the medium-term workstream. The previous hierarchy -- prioritising pension preservation for IHT-free transfer -- must be reassessed client by client. For clients with estates significantly above the nil-rate band, accelerated pension spending during lifetime may reduce IHT exposure, though this must be balanced against the income tax and CGT advantages that pensions continue to offer during accumulation and drawdown. The annual allowance and money purchase annual allowance constraints limit the ability to replenish pension funds, making the spend-down decision largely irreversible.

Coordination with will review is essential. The interaction between pension nominations and testamentary dispositions becomes more consequential when both pension and non-pension assets are within the IHT estate. Advisers should ensure that nominations and wills are reviewed in tandem, with consistent beneficiary designations and awareness of the proportional nil-rate band allocation.

Pre-Implementation Actions (Months 10-14)

Monitoring HMRC implementation guidance is critical. The policy paper confirms that HMRC will issue operational guidance before April 2027, including details of the income tax reclaim mechanism. Advisers should also verify the Finance Bill's parliamentary progress and adjust client communications if amendments are made during the legislative process.

Client communication should address the practical implications of the withholding mechanism, including the possibility of 15-month delays in benefit payment. Pre-mortem planning conversations -- while sensitive -- become necessary for clients with significant pension wealth where beneficiaries may face liquidity constraints. Establishing a documented process for these conversations, including file notes and client acknowledgement of the withholding risk, will support both regulatory compliance and professional liability management.

CPD Declaration

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

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the categories of pension death benefits that will fall within the IHT estate from April 2027 and those that are excluded from the charge.
  2. Calculate the combined income tax and IHT liability on pension death benefits for deaths occurring before and after age 75, applying proportional nil-rate band allocation.
  3. Evaluate beneficiary nomination strategies in light of the spousal exemption, charitable giving exemption, and the distinction between lump sum and drawdown benefit delivery.
  4. Apply the long-term UK resident test to determine IHT liability on pension death benefits for internationally mobile clients, including tail period analysis.
  5. Assess the implications of the 50% withholding mechanism for estate administration timelines and beneficiary liquidity planning.

FCA/CII Competency Mapping

  • Pension income options at retirement and death (RO3/RO8)
  • Inheritance tax planning and estate administration (AF1/AF5)
  • Pension death benefit taxation and nomination procedures (J05/R04)

Reflective Questions

  1. How would you restructure the nomination audit process within your practice to address the April 2027 changes, particularly for clients with spousal bypass trust arrangements?
  2. What criteria would you apply to determine whether accelerated pension spending is appropriate for a client whose estate exceeds the nil-rate band threshold, balancing IHT reduction against lifetime income tax and CGT advantages?
  3. How might the interaction between the residence-based IHT regime and pension death benefit taxation affect your advice to internationally mobile clients with UK pension entitlements?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 4 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 on unused pension funds and death benefits" -- Policy Paper (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  2. GOV.UK, "Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses" (21 July 2025). 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 ↩

  3. UK Parliament, Finance (No.2) Bill 2024-26 -- Parliamentary progress and programme order (first reading 2 December 2025; second reading 16 December 2025; PBC reporting deadline 26 February 2026). https://bills.parliament.uk/bills/4042 ↩ ↩2

  4. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Tax Information and Impact Note (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  5. HMRC Inheritance Tax Manual, IHTM47020 -- Long-term UK residence test (6 April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  6. HMRC Pensions Tax Manual, PTM073010 -- Tax on authorised lump sum death benefits (updated 6 April 2024). https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm073010 ↩

  7. Finance Act 2024, Schedule 9, paragraph 41 -- Abolition of lifetime allowance, introduction of LSA/LSDBA. https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/41 ↩

  8. HMRC Pensions Tax Manual, PTM073010 -- Beneficiary drawdown not tested against LSDBA (updated 6 April 2024). https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm073010 ↩

  9. HMRC Employment Income Manual, EIM75600 -- Taxation of pension income: death benefits. https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim75600 ↩

  10. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Policy Paper, Scope (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  11. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Policy Paper, Exclusions (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  12. GOV.UK, "Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses" (21 July 2025). 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 ↩

  13. GOV.UK, "Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses", Withholding Mechanism (21 July 2025). 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 ↩

  14. Professional Adviser, "Nasty shock? Personal representative duties post-6 April 2027 explained" (2025). https://www.professionaladviser.com/opinion/4522011/nasty-shock-personal-representative-duties-post-april-2027-explained ↩

  15. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Policy Paper, Business Relief exclusion (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  16. Aberdeen TechZone, "Pensions and IHT -- what it means for advice" (2025). https://techzone.aberdeenadviser.com/public/pensions/pensions-iht-means-for-advice ↩

  17. Sackers, "IHT and Pension Death Benefits: The road to 2027" (2025). https://www.sackers.com/blog/pensions-and-inheritance-tax/ ↩

  18. HMRC Pensions Tax Manual, PTM073010 -- Pre-75 death benefit taxation. https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm073010 ↩

  19. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Policy Paper, Income Tax Reclaim (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  20. HMRC Inheritance Tax Manual, IHTM17051 -- Pensions: IHT charges: death benefits introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm17051 ↩

  21. GOV.UK, "Inheritance Tax on unused pension funds and death benefits" -- Policy Paper (30 October 2024, updated 21 July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

  22. FCA Handbook, COBS 9 -- Suitability (including basic advice). https://www.handbook.fca.org.uk/handbook/COBS/9/ ↩ ↩2

  23. Hogan Lovells, "UK Pensions and Inheritance Tax (IHT): Revised Policy from HMRC" (2025). https://www.hoganlovells.com/en/publications/uk-pensions-and-inheritance-tax-iht-revised-policy-from-hmrc ↩

  24. Royal London for Advisers, "What is a spousal bypass trust?" (2025). https://adviser.royallondon.com/technical-central/pensions/death-benefits/what-is-a-spousal-bypass-trust/ ↩

  25. Wills Act 1837, s.18A (as inserted by Administration of Justice Act 1982, s.18(2)) -- Effect of dissolution or annulment of marriage on wills. https://www.legislation.gov.uk/ukpga/Will4and1Vict/7/26/section/18A ↩

  26. Aberdeen TechZone, "Death benefit nominations" (2025). https://techzone.aberdeenadviser.com/public/pensions/death-benefit-nominations ↩

  27. HMRC Inheritance Tax Manual, IHTM47020 -- Long-term UK residence test (6 April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

  28. Royal London for Advisers, "LTR and Non-dom inheritance tax" (2025). https://adviser.royallondon.com/technical-central/protection-guidance/inheritance-tax-and-related-manuals/long-term-resident-and-inheritance-tax/ ↩

  29. Dentons, "Pensions and inheritance tax: understanding the government's proposed changes" (August 2025). https://www.dentons.com/en/insights/articles/2025/august/6/pensions-and-inheritance-tax ↩

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