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Residence Nil-Rate Band Optimization: Technical Guidance for Financial Advisors

· 19 min

Executive Summary

The Residence Nil-Rate Band (RNRB), established by IHTA 1984 ss.8D-8M, provides up to GBP 175,000 of additional inheritance tax relief per person where a qualifying residential interest passes to direct descendants. With thresholds frozen through 2030-31 and HMRC data confirming 30,600 estates claimed RNRB in 2022-23, sheltering GBP 7.72 billion, the relief remains significant but technically demanding. The Office of Tax Simplification found the RNRB attracted more criticism than any other area of IHT. Three concurrent pressures now compound the planning imperative: fiscal drag from frozen thresholds, the inclusion of pension death benefits in the IHT estate from April 2027 (counting toward the GBP 2 million taper threshold), and the residence-based IHT regime enacted from April 2025. Financial advisors who master RNRB optimization -- including taper management, trust structuring, and downsizing provisions -- can deliver measurable IHT savings of up to GBP 140,000 per couple.

1. The RNRB Landscape: Frozen Thresholds and Rising Exposure

The RNRB was introduced by Finance (No. 2) Act 2015 s.9(4), inserting sections 8D to 8M into the Inheritance Tax Act 1984.1 The relief provides an additional nil-rate band, applicable to deaths on or after 6 April 2017, where a qualifying residential interest is "closely inherited" by direct descendants as defined by s.8K -- encompassing children, stepchildren, adopted children, foster children, grandchildren, and the spouses or civil partners of any lineal descendant.2

The RNRB reached its maximum of GBP 175,000 per person in 2020-21. Alongside the nil-rate band (NRB) at GBP 325,000 and the taper threshold at GBP 2 million, all three figures remain frozen through successive legislative extensions.3 Finance Act 2021 fixed thresholds through 2025-26; Finance Act 2023 extended through 2027-28; Finance Act 2025 extended through 2029-30; and the Finance (No. 2) Bill 2025-26, currently before Parliament, provides for a further extension through 2030-31.4 The statutory default under IHTA 1984 ss.8 and 8D(5) -- CPI indexation -- remains disapplied throughout the freeze period. Had the NRB tracked inflation from 2009, it would stand at approximately GBP 525,000.4

The fiscal impact of this extended freeze is material. HMRC collected GBP 8.2 billion in IHT during 2024-25, a record. In the first nine months of 2025-26, receipts reached GBP 6.6 billion, GBP 232 million higher than the equivalent period the previous year.5 The OBR forecasts IHT receipts of GBP 9.1 billion for 2025-26, rising to GBP 14.5 billion by 2030-31.56 In 2022-23, 4.62% of UK deaths (31,500 of 683,000) resulted in an IHT charge, equalling the previous 2016-17 high.7 Of those, 30,600 estates used the RNRB, sheltering GBP 7.72 billion of chargeable estate value -- a rise of GBP 1.21 billion from 2021-22.8

The complexity of the RNRB is well documented. The Office of Tax Simplification's second report on IHT found that the RNRB "attracted more comments than any other area of IHT" and concluded it is "too complex and people struggle to understand it."9 The OTS noted that some solicitors were declining to advise clients on the RNRB because of its complexity, potentially costing married couples up to GBP 140,000 in unnecessary IHT.9 The OTS calculated that replacing the RNRB with an enlarged NRB at equivalent exchequer cost would increase the NRB by only GBP 51,000 -- confirming that the RNRB's targeted design delivers materially greater relief per eligible estate than a universal threshold increase would achieve.9

This complexity creates both risk and opportunity for financial advisors. Those who can navigate the RNRB's technical requirements -- particularly the taper mechanism, trust interactions, and the forthcoming pension inclusion -- are positioned to deliver quantifiable tax savings that differentiate their advisory proposition.

2. The 60% Effective Rate: Understanding the Taper Mechanism

The RNRB taper threshold is GBP 2 million, as specified in IHTA 1984 s.8D(5)(b).10 For estates exceeding this value, the available RNRB reduces by GBP 1 for every GBP 2 of excess. The RNRB is fully extinguished at an estate value of GBP 2.35 million for a single allowance (GBP 175,000 x 2 = GBP 350,000 above GBP 2 million). Where the full transferable RNRB (TRNRB) from a predeceased spouse is available, the combined allowance of GBP 350,000 is fully lost at GBP 2.7 million.1011

The 60% Marginal Rate Calculation

The interaction between the 40% IHT rate and the taper withdrawal creates a 60% effective marginal rate within the tapering band. Each additional GBP 2 of estate value above GBP 2 million attracts GBP 0.80 of IHT (GBP 2 x 40%), plus the loss of GBP 1 of RNRB relief -- itself worth GBP 0.40 at the 40% rate. The combined tax cost of GBP 1.20 on GBP 2 of value equates to 60%.1011

Worked example -- single person's estate at GBP 2.2 million:

  • Estate above taper threshold: GBP 200,000
  • RNRB reduction: GBP 200,000 / 2 = GBP 100,000
  • Remaining RNRB: GBP 75,000 (GBP 175,000 - GBP 100,000)
  • IHT payable without taper: (GBP 2,200,000 - GBP 325,000 NRB - GBP 175,000 full RNRB) x 40% = GBP 680,000
  • IHT payable with taper: (GBP 2,200,000 - GBP 325,000 NRB - GBP 75,000 tapered RNRB) x 40% = GBP 720,000
  • Additional IHT from taper: GBP 40,000
  • Effective marginal rate on the GBP 200,000 excess: GBP 120,000 total IHT on that band / GBP 200,000 = 60%

The Net Estate Definition: A Critical Distinction

The "net estate" for taper purposes diverges from the standard chargeable estate in several material respects. HMRC guidance at IHTM46012 confirms that the estate value ("E") used in the taper calculation includes assets qualifying for business property relief (BPR) or agricultural property relief (APR) at their full value -- without deducting the relief.12 It also includes assets passing to the surviving spouse, without deducting the spousal exemption.12 This means that a married couple where the first spouse leaves the entire estate to the survivor may have a taper estate of GBP 2.5 million even though no IHT is payable on first death due to the spousal exemption.

Conversely, lifetime gifts are excluded from the taper estate. Even where a potentially exempt transfer (PET) falls within the seven-year period and is chargeable on death, the gifted property is not included in the taper calculation because it was not owned at the date of death.1213 This asymmetry is a powerful planning lever: a lifetime gift of GBP 200,000 reduces the taper estate immediately by that amount, regardless of whether the donor survives seven years. The IHT on the failed PET is a separate calculation that does not interact with the RNRB taper.12

The reformed APR/BPR regime from April 2026, which introduces a GBP 1 million combined cap on 100% relief, does not alter this position. Assets qualifying for APR or BPR continue to be included in the taper estate at full value, irrespective of the relief available against them.12

3. April 2027: Pension Death Benefits as a Taper Trigger

The Finance (No. 2) Bill 2025-26, currently progressing through Parliament (Public Bill Committee stage as of February 2026, with Royal Assent expected later in 2026), provides for the inclusion of unspent defined contribution (DC) pension funds in the deceased's estate for IHT purposes from 6 April 2027.14 For RNRB planning, the critical consequence is that pension values will count toward the GBP 2 million taper threshold, potentially triggering partial or complete loss of the RNRB for estates that were previously below the threshold.1415

Quantifying the Pension-Taper Interaction

Worked example -- estate with pension pot:

Consider an estate comprising property (GBP 800,000), investments (GBP 700,000), and other assets (GBP 450,000), totalling GBP 1.95 million -- comfortably below the taper threshold. The individual also holds a GBP 500,000 DC pension pot. Under current rules, the pension is outside the IHT estate and the full RNRB of GBP 175,000 is available.

From April 2027, the taper estate becomes GBP 2.45 million. The RNRB reduction is calculated as (GBP 2,450,000 - GBP 2,000,000) / 2 = GBP 225,000. Since GBP 225,000 exceeds the maximum RNRB of GBP 175,000, the relief is entirely eliminated. The additional IHT cost attributable to the lost RNRB is GBP 70,000 (GBP 175,000 x 40%).1415

For couples with full TRNRB entitlement, the effect may be partially mitigated where the combined RNRB allowance is GBP 350,000. However, pension wealth is frequently concentrated in one spouse, creating an asymmetric taper exposure on the second death where estates "bunch" as assets consolidate in the surviving spouse's estate.15

Planning Responses: Pension Drawdown and RNRB Preservation

The pension-taper interaction introduces a coordination requirement between pension decumulation strategy and RNRB preservation. Accelerating pension drawdown to reduce the DC fund below the level that triggers taper loss may be advantageous, despite the income tax charge on withdrawals.16

The trade-off analysis depends on the client's marginal income tax rate. Where a pension withdrawal is taxed at 40% income tax, the net cost of extracting GBP 100,000 from the pension is GBP 40,000. However, if retaining that GBP 100,000 in the pension would reduce the RNRB by GBP 50,000 (triggering GBP 20,000 of additional IHT), the net benefit of withdrawal is GBP 20,000 minus the opportunity cost of losing pension tax wrapper growth. For higher-rate taxpayers approaching the taper threshold, staged drawdown over multiple tax years to utilise basic-rate bands and the personal allowance may optimise the income tax versus IHT trade-off.16

Advisors should model the pension-taper interaction for all clients with estates in the GBP 1.5-2.5 million range, accounting for projected asset growth and the income tax implications of accelerated drawdown. The April 2027 implementation date provides a defined planning window, but effective mitigation strategies require lead time for phased pension withdrawals across multiple tax years.

4. Trust Structures: Preserving and Destroying the RNRB

The "closely inherited" requirement in IHTA 1984 s.8E creates a binary outcome for trust structures: the qualifying residential interest must pass to a direct descendant in a manner that satisfies the statutory definition, or the RNRB is lost.17

Discretionary Will Trusts: The Default Failure

Discretionary will trusts defeat the RNRB because no individual beneficiary has a present entitlement to the trust property -- the trustees' discretion means the residential interest is not "closely inherited" by any person.17 This is the single most common structural barrier to RNRB claims in existing estates.

However, IHTA 1984 s.144 provides a remedial mechanism. Where trustees of a will trust make an appointment to a direct descendant within two years of the death, the appointment is treated for IHT purposes as if the deceased had left the assets directly to that beneficiary.18 This two-year window is a critical post-death planning tool, but it requires proactive action by the personal representatives or trustees. Failure to make the appointment within the statutory period extinguishes the opportunity permanently.18

Trust Structures That Preserve the RNRB

Several trust types satisfy the "closely inherited" test:1719

  • Immediate post-death interest (IPDI) trusts: The beneficiary holds an immediate right to income from the trust property. Where the IPDI beneficiary is a direct descendant, the qualifying residential interest is treated as closely inherited.
  • Bereaved minor trusts (IHTA 1984 s.71A): Applicable where a minor loses a parent, with assets held on statutory trusts. The trust must vest absolutely at age 18 or on marriage/civil partnership before that age.
  • 18-25 trusts (IHTA 1984 s.71D): Capital held for the beneficiary until they reach age 25, with an exit charge on capital distributions between ages 18 and 25.
  • Disabled person's trusts (IHTA 1984 s.89): Meeting the statutory conditions for trusts established for disabled beneficiaries.

The Age-Contingent Gift Trap

Where a will leaves property to a descendant contingent on attaining an age above 18, the gift creates a relevant property trust during the contingency period. For children of the deceased, s.71A bereaved minor trust treatment may apply, preserving the RNRB. For grandchildren, however, no equivalent automatic provision exists unless the grandchild held an IPDI, rendering the RNRB unavailable during the contingency period.1719 Will drafting should either remove age contingencies above 18 or structure the gift through an 18-25 trust where the RNRB benefit outweighs the exit charge exposure.

Legacy Will Drafting Risk: Pre-2017 NRB Discretionary Trusts

Pre-2017 wills commonly included NRB discretionary trusts directing the first GBP 325,000 of the estate (frequently including the family home or a share of it) into a discretionary trust on the first death. This structure, once standard estate planning practice, now risks sacrificing the RNRB unless trustees make a s.144 appointment within two years.20

The scale of this legacy risk is substantial. Wills drafted before April 2017 could not have contemplated the RNRB, and many remain unrevised. A systematic will review programme -- coordinated between financial advisors and solicitors -- is warranted to identify clients whose existing will structures inadvertently defeat the RNRB. Advisors facilitating such reviews should ensure compliance with COBS suitability obligations and recommend specialist legal advice for any will restructuring, maintaining clear professional boundaries with solicitors.209

Deeds of Variation: Post-Death Remedy

IHTA 1984 s.142 permits a deed of variation within two years of death, with the varied disposition treated as if made by the deceased. This provides a post-death remedy where a will's provisions defeat the RNRB. However, reliance on post-death variation as a planning strategy carries inherent uncertainty: the variation requires the consent of all beneficiaries adversely affected, and the ability to vary post-death remains subject to potential policy reform.18

5. Downsizing, Estate Equalisation, and the Residence-Based Regime

The Downsizing Provisions: IHTA 1984 ss.8FA-8FE

The downsizing provisions address circumstances where the deceased disposed of a qualifying residential interest on or after 8 July 2015, either by moving to a less valuable property or leaving residential property altogether.21 Section 8FA applies where a lesser residential interest remains in the estate; s.8FB applies where no residential interest remains at death.22

The "downsizing addition" compensates for RNRB lost due to the disposal, up to the maximum RNRB that would have been available on the disposed property. The combined RNRB and downsizing addition cannot exceed the residential enhancement for the year of death (GBP 175,000).21

Critically, the downsizing claim is not automatic. Personal representatives must file form IHT435 within two years of the end of the month of death.23 Advisory practices should incorporate this deadline into probate checklists as a standard operational procedure. Where multiple disposals have occurred since 8 July 2015, personal representatives may select the disposal that generates the most beneficial claim.24

Care home scenario: Where a client moves into residential care and sells the family home, the downsizing provisions can preserve the RNRB provided equivalent assets from the sale proceeds (or otherwise) pass to direct descendants.24 However, a limitation applies where the deceased occupied the property under the terms of a trust and the trustees (rather than the deceased personally) sold or downsized the property -- in such cases, the downsizing provisions do not apply.24

Estate Equalisation Between Spouses

The interaction between RNRB, TRNRB, and the taper threshold creates a strategic question on the first death: should the RNRB be used immediately, or carried forward as transferable RNRB to the surviving spouse?

Where the surviving spouse's estate will exceed GBP 2 million (including assets inherited from the first spouse), carrying forward the RNRB risks exposure to the taper on the second death. The "bunching effect" -- where assets consolidate in the surviving spouse's estate -- can push the second-death estate above the taper threshold, reducing or eliminating both the individual RNRB and the TRNRB.1011

Strategies to mitigate bunching include:

  • Tenancy in common arrangements: Severing a joint tenancy so that each spouse owns a defined share of the family home, enabling the first spouse's share to pass to descendants (using the RNRB) rather than to the survivor by survivorship.
  • NRB discretionary trust on first death: Directing NRB-sheltered assets into a discretionary trust while ensuring the residential interest passes directly to descendants (or into an RNRB-qualifying trust), consuming the first spouse's RNRB on first death.
  • Lifetime gifting by the wealthier spouse: Reducing the taper estate through lifetime gifts, which are excluded from the taper calculation immediately.12

The optimal strategy depends on the relative values of each spouse's estate, the availability of BPR/APR qualifying assets, and the projected growth trajectory of the surviving spouse's estate. Financial modelling across both deaths is essential to determining the most tax-efficient sequencing of RNRB utilisation.

The Residence-Based IHT Regime: Implications for RNRB Planning

The residence-based IHT regime, enacted from 6 April 2025, replaced the domicile-based system with a long-term resident (LTR) test.25 Any individual resident in the UK for 10 of the preceding 20 tax years is subject to IHT on worldwide assets. Tail provisions maintain IHT liability for 3-10 years after departure from the UK, depending on the length of residence.25

For RNRB purposes, the key interaction is the taper calculation. Long-term UK residents face a taper threshold of GBP 2 million measured against the worldwide estate. Overseas assets -- investment portfolios, foreign property, international business interests -- count toward the taper threshold in full, potentially reducing or eliminating the RNRB even where the UK residential property passing to descendants is relatively modest.26

Worked example -- internationally mobile client:

A long-term UK resident holds a UK home (GBP 600,000), UK investments (GBP 400,000), and overseas assets (GBP 1.2 million). The worldwide estate totals GBP 2.2 million. The RNRB reduction is (GBP 2,200,000 - GBP 2,000,000) / 2 = GBP 100,000, leaving only GBP 75,000 of available RNRB. The overseas assets -- over which the client may have limited restructuring flexibility -- trigger a GBP 40,000 increase in IHT attributable to RNRB taper loss.26

For non-LTR individuals with UK-situs assets, the NRB and RNRB remain available against the UK estate, with the taper calculation based on the UK-situs estate only.26

An additional complexity arises for couples where one spouse is an LTR and the other is not. The spousal exemption under the new regime is restricted to GBP 325,000 cumulatively for transfers from an LTR to a non-LTR spouse, unless the non-LTR spouse elects to be treated as an LTR.25 This restriction affects estate equalisation strategies: assets transferred in excess of GBP 325,000 to a non-LTR spouse are immediately chargeable, limiting the ability to manage the taper through inter-spousal transfers.

Conclusion

RNRB optimization is not a passive exercise. The convergence of three structural pressures -- threshold freeze through 2030-31, pension death benefit inclusion from April 2027, and the residence-based IHT regime enacted from April 2025 -- demands that financial advisors integrate RNRB planning into a coordinated estate and financial planning framework.

The technical complexity that led the OTS to characterise the RNRB as the most criticised area of IHT is precisely what creates the advisory opportunity. Advisors who can model the 60% effective marginal rate, quantify the pension-taper interaction for individual clients, identify legacy will structures that defeat the RNRB, and coordinate downsizing provisions with estate equalisation strategies deliver measurable value -- up to GBP 140,000 of IHT savings for a married couple with full RNRB and TRNRB entitlement.9

Three priorities merit immediate attention. First, clients with estates in the GBP 1.5-2.5 million range should have their pension-taper exposure modelled before April 2027. Second, a systematic review of pre-2017 wills for NRB discretionary trust provisions should be initiated in coordination with solicitors. Third, internationally mobile clients should have their worldwide estate assessed against the taper threshold under the new residence-based regime.

The RNRB was designed to deliver targeted IHT relief for the family home. Realising that design intent requires technical competence and proactive planning -- attributes that distinguish specialist advisory practices in an increasingly complex inheritance tax landscape. With thresholds frozen for at least another five years, the planning window is both extended and urgent: fiscal drag will continue to draw more estates into the taper band, making RNRB optimization an increasingly central component of holistic financial advice.

CPD Declaration

Estimated Reading Time: 19 minutes Technical Level: Advanced Practice Areas: Estate Planning, Inheritance Tax, Pension Planning, Trust Structuring

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the legislative framework for the RNRB (IHTA 1984 ss.8D-8M) and its qualifying conditions, including the "closely inherited" requirement and the taper threshold mechanism.
  2. Calculate the RNRB taper reduction and the 60% effective marginal rate for estates exceeding GBP 2 million, including the distinct "net estate" definition used for taper purposes.
  3. Evaluate the impact of defined contribution pension death benefit inclusion from April 2027 on RNRB availability through the taper threshold, and assess pension drawdown strategies as a planning response.
  4. Distinguish between trust structures that preserve the RNRB (IPDI, bereaved minor, 18-25, disabled person's trusts) and those that defeat it (discretionary trusts without a s.144 appointment).
  5. Assess the application of downsizing provisions (IHTA 1984 ss.8FA-8FE) and estate equalisation strategies to specific client scenarios, including the interaction with the residence-based IHT regime.

CII/PFS Competency Mapping

  • AF1: Personal Tax and Trust Planning -- IHT reliefs, trust taxation, estate planning strategies
  • AF5: Financial Planning Process -- holistic financial planning integrating tax, pension, and estate considerations

SRA Competency Mapping

  • A2: Maintain the level of competence and legal knowledge needed to practise effectively
  • B6: Ensure compliance with legal and regulatory requirements

Note: SRA competencies included for cross-professional reference where advisors collaborate with solicitors on estate planning matters.

Reflective Questions

  1. How many clients within your advisory practice have estates in the GBP 1.8-2.5 million range, and has the impact of pension values on the RNRB taper been modelled for each?
  2. What proportion of clients' existing wills contain NRB discretionary trust provisions predating the RNRB introduction, and what process exists to identify and review these?
  3. How does your practice coordinate RNRB planning with pension drawdown strategy, particularly for clients approaching the April 2027 pension IHT inclusion?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. 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. Finance (No. 2) Act 2015, s.9(4) -- Insertion of IHTA 1984 ss.8D-8M. https://www.legislation.gov.uk/ukpga/2015/33/notes/division/3/index.htm ↩

  2. IHTA 1984 s.8K -- Meaning of "closely inherited." https://www.legislation.gov.uk/ukpga/1984/51/section/8K ↩

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

  4. GOV.UK -- IHT NRB and RNRB from 6 April 2028. https://www.gov.uk/government/publications/inheritance-tax-nil-rate-band-and-residence-nil-rate-bands-from-6-april-2028/inheritance-tax-nil-rate-band-residence-nil-rate-band-from-6-april-2028 ↩ ↩2

  5. HMRC -- Tax and NICs receipts for the United Kingdom (January 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-united-kingdom ↩ ↩2

  6. Professional Adviser -- "IHT receipts continue on path to record year." https://www.professionaladviser.com/news/4523536/iht-receipts-continue-path-record ↩

  7. HMRC -- IHT liabilities statistics commentary (July 2025). https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩

  8. HMRC -- Inheritance Tax statistics commentary (July 2025). https://www.gov.uk/government/statistics/inheritance-tax-statistics-commentary/inheritance-tax-statistics-commentary ↩

  9. OTS -- Inheritance Tax review: second report (July 2019). https://www.gov.uk/government/publications/office-of-tax-simplification-inheritance-tax-review ↩ ↩2 ↩3 ↩4 ↩5

  10. HMRC IHTM46023 -- Calculating the RNRB: the taper threshold. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46023 ↩ ↩2 ↩3 ↩4

  11. M&G Wealth Adviser -- Residence Nil Rate Band Planning. https://www.mandg.com/wealth/adviser-services/tech-matters/iht-and-estate-planning/nil-rate-bands/residence-nil-rate-band-planning ↩ ↩2 ↩3

  12. HMRC IHTM46012 -- The value of the estate 'E' and the value transferred on death 'VT'. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46012 ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  13. M&G Wealth Adviser -- Residence Nil Rate Band Facts. https://www.mandg.com/wealth/adviser-services/tech-matters/iht-and-estate-planning/nil-rate-bands/residence-nil-rate-band-facts ↩

  14. GOV.UK -- Inheritance Tax changes (pension death benefits). https://www.gov.uk/government/publications/inheritance-tax-changes ↩ ↩2 ↩3

  15. VWV -- Changes to inheritance tax on pensions: what to expect from April 2027. https://www.vwv.co.uk/insights/articles/changes-to-inheritance-tax-on-pensions-what-to-expect-from-april-2027/ ↩ ↩2 ↩3

  16. Buckles Law -- The impact of Inheritance Tax reform on pension funds. https://www.buckles-law.co.uk/blog/private-wealth/the-impact-of-inheritance-tax-reform-on-pension-funds/ ↩ ↩2

  17. Aberdeen Adviser TechZone -- Residence nil rate band guide. https://techzone.aberdeenadviser.com/public/iht-est-plan/residence-nil-rate-band-guide ↩ ↩2 ↩3 ↩4

  18. IHTA 1984 s.144 -- Distribution from property settled by will. https://www.legislation.gov.uk/ukpga/1984/51/section/144 ↩ ↩2 ↩3

  19. M&G Wealth Adviser -- Residence Nil Rate Band Facts. https://www.mandg.com/wealth/adviser-services/tech-matters/iht-and-estate-planning/nil-rate-bands/residence-nil-rate-band-facts ↩ ↩2

  20. PFS -- A review of the residence nil rate band and its impact on IHT planning. https://www.thepfs.org/news-insight/news/articles/a-review-of-the-residence-nil-rate-band-and-its-impact-on-iht-planning/15f40125-0341-4d3a-be1b-b24afe6d42ba ↩ ↩2

  21. IHTA 1984 s.8FA -- Downsizing addition: entitlement. https://www.legislation.gov.uk/ukpga/1984/51/section/8FA ↩ ↩2

  22. IHTA 1984 s.8FE -- Calculation of lost relievable amount. https://www.legislation.gov.uk/ukpga/1984/51/section/8FE ↩

  23. IHT435 -- Claim for residence nil rate band (RNRB). https://assets.publishing.service.gov.uk/media/67ee9503e9c76fa33048c768/claim-for-residence-nil-rate-band-iht435.pdf ↩

  24. GOV.UK -- Work out and apply the residence nil rate band for Inheritance Tax. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩ ↩2 ↩3

  25. GOV.UK -- Inheritance Tax changes (residence-based regime). https://www.gov.uk/government/publications/inheritance-tax-changes ↩ ↩2 ↩3

  26. Leo Wealth -- 2025 UK Inheritance Tax Guide. https://leowealth.com/insights/2025-uk-inheritance-tax-iht-guide/ ↩ ↩2 ↩3

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