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Residential Property Estate Planning: RNRB Technical Deep Dive for Accountants

· 21 min

Executive Summary

The residence nil-rate band under IHTA 1984 ss.8D-8M represents up to GBP 175,000 per person in IHT relief, yet the Office of Tax Simplification concluded it attracted more practitioner criticism than any other area of inheritance tax.1 With IHT receipts reaching GBP 7.1 billion in the first ten months of 2025-26 and all thresholds frozen through at least 2029-30, three concurrent developments demand fresh technical analysis.23 Pension death benefit inclusion from April 2027 will push estates above the GBP 2 million taper threshold, triggering a 60% effective marginal rate. APR/BPR reforms from April 2026 interact counterintuitively with the taper calculation because relievable assets inflate the estate value "E" under IHTM46012.45 The downsizing addition under ss.8FA-8FE remains underutilised despite offering a mechanism to recover lost relief. This article provides accountants with a unified technical framework encompassing taper mechanics, pension impact modelling, trust structure analysis, and procedural compliance.

1. Introduction: Why RNRB Mastery Matters Now

The residence nil-rate band was introduced by Finance (No. 2) Act 2015 s.9, which inserted sections 8D to 8M into the Inheritance Tax Act 1984, applicable to deaths on or after 6 April 2017.67 The relief provides an additional nil-rate amount of GBP 175,000 where a qualifying residential interest passes to direct descendants, supplementing the standard NRB of GBP 325,000. For a married couple or civil partners with full transferability, the combined RNRB of GBP 350,000 can deliver IHT savings of up to GBP 140,000 at the 40% rate.8

Despite these material sums, the RNRB has proved to be one of the most technically demanding reliefs in the IHT system. The OTS second report on IHT in July 2019 found it "attracted more comments than any other area of IHT" and concluded the relief is "too complex and people struggle to understand it."1 The report noted some solicitors were declining to advise on the RNRB because of its complexity, potentially costing married couples the full GBP 140,000 saving.

The planning environment has become more complex since that assessment. Three concurrent legislative developments reshape the RNRB landscape for 2026 and beyond:

First, pension death benefits will be included in the IHT estate from 6 April 2027 under provisions in the Finance (No. 2) Bill 2025-26.9 DC pension funds will count toward the GBP 2 million taper threshold, pushing estates that were previously below the threshold into a 60% effective marginal rate band.

Second, APR/BPR reforms from 6 April 2026 cap 100% relief at GBP 2.5 million per individual, with 50% relief above that threshold.5 For mixed estates containing agricultural or business property alongside residential property, the interaction between these reliefs and the RNRB taper demands careful modelling.

Third, the threshold freeze -- NRB at GBP 325,000, RNRB at GBP 175,000, and the taper threshold at GBP 2 million -- is enacted through 2029-30 under Finance Act 2025, with further extension to 2030-31 in Finance (No. 2) Bill 2025-26.310 Fiscal drag continues to draw more estates into the taper band.

HMRC data confirms the relief's fiscal significance: 30,600 estates claimed the RNRB in 2022-23, sheltering GBP 7.72 billion of chargeable estate value -- a rise of GBP 1.21 billion from 2021-22.11 IHT receipts reached GBP 7.1 billion in the first ten months of 2025-26, with the OBR forecasting GBP 8.7 billion for the full year in its November 2025 Economic and Fiscal Outlook.2 Against this backdrop, accountants who master the RNRB's calculation mechanics, taper management strategies, and procedural requirements deliver material value to their estate administration and planning clients.

2. Legislative Framework and Core Mechanics

2.1 The Statutory Structure: ss.8D-8M

The RNRB operates through a series of interconnected statutory provisions. Section 8D is the primary operative section: where the person's "residence nil-rate amount" exceeds zero, the portion of VT (value transferred) not exceeding that amount is charged at 0%.12 Section 8D(5) defines the key terminology:

  • Residential enhancement: GBP 175,000 from 2020-21 onward (the RNRB maximum per person)
  • Taper threshold: GBP 2 million (above which the RNRB is progressively withdrawn)
  • Default allowance: The residential enhancement plus any brought-forward allowance from a predeceased spouse
  • Adjusted allowance: The default allowance reduced by the taper12

Section 8E governs the calculation where the estate includes a qualifying residential interest (QRI) that is closely inherited: the residence nil-rate amount is the lower of the QRI value and the default or adjusted allowance.13 Where the estate does not include a QRI, or includes one that is not closely inherited, section 8F applies and the residence nil-rate amount is nil -- though the full allowance remains available for carry-forward to a surviving spouse under s.8G.1415

2.2 Qualifying Residential Interest

A QRI is defined in section 8H as an interest in a dwelling-house that at some point during the deceased's period of ownership was their residence.16 IHTM46011 provides detailed guidance, confirming that shares in jointly held property qualify and that the property need not have been the deceased's main residence at the date of death.17 A QRI can be situated outside the UK, provided it was the deceased's residence. For individuals who are not long-term UK residents under the residence-based IHT regime enacted from 6 April 2025, only UK-situs property falls within the IHT estate, and the RNRB can only apply to UK property.18

2.3 The "Closely Inherited" Test

Section 8K defines "closely inherited" as passing to lineal descendants, encompassing biological children, stepchildren, adopted children, foster children (where the relationship was established before the child's 18th birthday), children under guardianship or special guardianship, grandchildren, and their spouses or civil partners.1920

Several exclusions create common planning pitfalls. Children of a cohabiting partner from a previous relationship do not qualify as stepchildren unless the couple are married or in a civil partnership -- the statutory step-relationship requires a legal bond between the adults.19 Parents, siblings, nephews, and nieces are excluded regardless of their closeness to the deceased. Surviving spouses of predeceased lineal descendants qualify provided they have not remarried.20

The QRI must be "inherited" in the statutory sense: passing under the will, on intestacy, by right of survivorship (joint tenants), or through certain qualifying trust mechanisms (addressed in Section 6 below).21

3. The Taper Mechanism and the 60% Effective Marginal Rate

3.1 Taper Mechanics

Where the estate value "E" exceeds the GBP 2 million taper threshold, the RNRB is reduced by GBP 1 for every GBP 2 of excess, per IHTA 1984 s.8D(5) and IHTM46023.22 For a single allowance of GBP 175,000, the RNRB is fully extinguished when "E" reaches GBP 2,350,000. Where the full transferable RNRB is available (GBP 350,000), extinguishment occurs at GBP 2,700,000.822

The GBP 1-for-GBP 2 withdrawal creates an effective 60% marginal IHT rate within the taper band. Each additional GBP 2 of estate value above GBP 2 million attracts GBP 0.80 of IHT at the 40% headline rate, plus the loss of GBP 1 of RNRB worth GBP 0.40 at the 40% rate. The combined cost of GBP 1.20 on GBP 2 of estate produces a 60% effective marginal rate -- 50% higher than the headline rate.2223

3.2 Worked Example: Taper Calculation

Margaret dies in 2026-27 with an estate valued at GBP 2,400,000. She is a widow with full TRNRB available (her late husband's 100% unused RNRB). The residential property (GBP 600,000) passes to her daughter.

  • Estate value "E": GBP 2,400,000
  • Taper threshold: GBP 2,000,000
  • Excess: GBP 400,000
  • RNRB reduction: GBP 400,000 / 2 = GBP 200,000
  • Default allowance (own RNRB + TRNRB): GBP 175,000 + GBP 175,000 = GBP 350,000
  • Adjusted allowance: GBP 350,000 - GBP 200,000 = GBP 150,000
  • NRB: GBP 325,000 + GBP 325,000 = GBP 650,000
  • Total nil-rate relief: GBP 650,000 + GBP 150,000 = GBP 800,000
  • Chargeable estate: GBP 2,400,000 - GBP 800,000 = GBP 1,600,000
  • IHT liability: GBP 640,000

Had the estate been GBP 2,000,000 (GBP 400,000 lower), the full RNRB of GBP 350,000 would have been available. Total nil-rate relief would be GBP 1,000,000, with a chargeable estate of GBP 1,000,000 and IHT of GBP 400,000. The additional GBP 400,000 of estate value costs GBP 240,000 in IHT -- an effective 60% rate on that marginal increment.2223

3.3 The Critical Definition of "E"

IHTM46012 defines the estate value "E" for taper purposes as all property to which the person was beneficially entitled at death, including settled property where they held a qualifying interest in possession and gifts with reservation. Crucially, "E" is calculated after deducting liabilities but before deducting exemptions (including spousal exemption) and reliefs (APR/BPR).4

This produces three counterintuitive consequences:

  1. An estate passing entirely to a surviving spouse still has a taper estate equal to the gross estate value (less liabilities), even though no IHT is payable on the spousal transfer
  2. Agricultural and business property is included at full value, irrespective of APR/BPR entitlement
  3. Lifetime gifts -- including failed PETs within the seven-year period -- are excluded from "E" because they were not owned at the date of death423

The third point is the most powerful planning lever. A lifetime gift of GBP 200,000 immediately reduces the taper estate by that amount, regardless of survival. Because the gift operates within the 60% marginal rate band, the effective IHT saving from taper preservation can be GBP 120,000 (60% of GBP 200,000), not the GBP 80,000 (40%) that a simple IHT rate analysis would suggest.4

4. APR/BPR Interaction with the RNRB Taper

4.1 The Counterintuitive Taper Estate Calculation

Because IHTM46012 specifies that "E" is calculated before deducting reliefs, agricultural and business property inflates the taper estate regardless of whether APR or BPR ultimately applies to reduce the IHT charge.4 This creates a planning tension that is frequently misunderstood: an estate may qualify for substantial APR/BPR, reducing or eliminating the IHT charge on the relievable assets, while simultaneously losing the RNRB through taper withdrawal triggered by those same assets.

4.2 Worked Example: Mixed Agricultural and Residential Estate

Robert dies in 2026-27 with the following estate:

  • Farmland and buildings (qualifying for 100% APR): GBP 2,000,000
  • Family home (QRI, passing to his son): GBP 500,000
  • Other assets: GBP 300,000
  • Total estate: GBP 2,800,000

Taper calculation:

  • Estate value "E" (before reliefs): GBP 2,800,000
  • Taper threshold: GBP 2,000,000
  • Excess: GBP 800,000
  • RNRB reduction: GBP 800,000 / 2 = GBP 400,000
  • RNRB default allowance: GBP 175,000
  • Adjusted allowance: GBP 175,000 - GBP 400,000 = nil (fully extinguished)

IHT calculation:

  • Agricultural property relief (100% on first GBP 2,000,000, within the GBP 2.5 million per-individual cap from April 2026): GBP 2,000,0005
  • Chargeable value after APR: GBP 2,800,000 - GBP 2,000,000 = GBP 800,000
  • NRB: GBP 325,000
  • RNRB: nil (fully tapered)
  • Chargeable estate: GBP 800,000 - GBP 325,000 = GBP 475,000
  • IHT liability: GBP 190,000

Had the taper estate been calculated after deducting APR, "E" would have been GBP 800,000 -- well below the GBP 2 million threshold -- and the full RNRB of GBP 175,000 would have been available. The IHT liability would then be GBP 120,000, a GBP 70,000 difference. Accountants advising farming and business-owning clients must model this interaction explicitly.424

4.3 April 2026 APR/BPR Reforms and Taper Implications

The new GBP 2.5 million per-individual cap on 100% APR/BPR (with 50% relief above that threshold) does not alter the taper calculation methodology -- the taper continues to operate on gross estate value before relief.54 However, the reforms create an additional layer of planning complexity for larger mixed estates. An estate with GBP 4 million of agricultural property now receives 100% APR on the first GBP 2.5 million and 50% on the remaining GBP 1.5 million, while the full GBP 4 million counts toward the taper estate. The APR/BPR allowance is transferable between spouses, providing scope for estate planning through inter-spousal asset allocation.5

5. Pension Death Benefit Inclusion from April 2027

5.1 The Taper Trigger

Under provisions in Finance (No. 2) Bill 2025-26, unspent DC pension funds and pension death benefits will be included in the estate for IHT from 6 April 2027.9 The critical RNRB consequence is that pension values will count toward the GBP 2 million taper threshold. While HMRC has not yet published updated IHTM46012 guidance explicitly confirming that pension funds within the estate will count toward "E" for taper purposes, this is the logical interpretation of the statutory framework: pensions become part of the estate, and "E" includes all estate assets.925

5.2 Worked Example: Pension-Taper Cascading Effect

Helen dies in April 2028 with the following estate:

  • Family home (QRI, passing to her daughter): GBP 450,000
  • Investments and savings: GBP 1,300,000
  • DC pension fund (unspent): GBP 500,000
  • Total estate: GBP 2,250,000

Without pension inclusion (pre-April 2027 position):

  • Estate value "E": GBP 1,750,000 (excluding pension)
  • Below taper threshold: full RNRB of GBP 175,000 available
  • NRB + RNRB: GBP 500,000
  • Chargeable estate: GBP 1,750,000 - GBP 500,000 = GBP 1,250,000
  • IHT: GBP 500,000

With pension inclusion (from April 2027):

  • Estate value "E": GBP 2,250,000 (including pension)
  • Excess over taper threshold: GBP 250,000
  • RNRB reduction: GBP 250,000 / 2 = GBP 125,000
  • Adjusted RNRB: GBP 175,000 - GBP 125,000 = GBP 50,000
  • NRB + adjusted RNRB: GBP 375,000
  • Chargeable estate: GBP 2,250,000 - GBP 375,000 = GBP 1,875,000
  • IHT: GBP 750,000

The pension inclusion increases the IHT liability by GBP 250,000 -- comprising GBP 200,000 on the pension fund itself plus GBP 50,000 from lost RNRB. The RNRB erosion costs an additional GBP 50,000 beyond the direct pension taxation.925

5.3 Planning Responses

Several strategies merit analysis for estates where pension inclusion will trigger taper exposure:

Accelerated pension drawdown reduces the DC fund size but generates income tax. For basic-rate taxpayers, the income tax cost of drawdown (20%) is substantially lower than the combined IHT and RNRB taper cost (up to 60% effective marginal rate in the taper band). For higher-rate taxpayers, staged drawdown across multiple tax years to utilise basic-rate bands can optimise the trade-off.26

Lifetime gifts of non-pension assets reduce the taper estate immediately, since gifts are excluded from "E". A gift of GBP 250,000 from Helen's investment portfolio would reduce her taper estate below GBP 2 million, restoring the full RNRB -- an effective 60% saving within the taper band.4

Pension nomination to surviving spouse applies the spousal exemption to pension death benefits, removing them from the taper calculation on the first death. This defers the taper risk to the second death, where the TRNRB may provide additional relief.9

Exceptions to the pension inclusion should also be noted: death-in-service benefits paid while still employed and dependants' scheme pensions from defined benefit schemes generally remain outside the IHT estate.9

6. Trust Structures and the RNRB

6.1 Binary Outcomes

The "closely inherited" requirement under s.8K creates binary outcomes for trust structures holding the qualifying residential interest.2027

Trusts that defeat the RNRB:

  • Discretionary will trusts: No individual beneficiary has present entitlement to the residential interest; the QRI is not "closely inherited" and the RNRB is lost
  • Relevant property trusts where no appointment is made within the s.144 window
  • Age-contingent gifts to grandchildren with age conditions above 18: these create a relevant property trust during the contingency period, defeating the RNRB until the condition is satisfied2728

Trusts that preserve the RNRB:

  • Immediate post-death interest (IPDI) trusts: The beneficiary holds an immediate right to income; where the beneficiary is a direct descendant, the QRI is treated as closely inherited
  • Bereaved minor trusts (s.71A): Applicable where a minor loses a parent, with the trust vesting absolutely at age 18
  • 18-25 trusts (s.71D): Capital held until age 25, with an exit charge on distributions between 18 and 25
  • Disabled person's trusts (s.89): Meeting statutory disability conditions2728

6.2 The s.144 Remedial Mechanism

Where trustees of a discretionary will trust appoint the QRI to a direct descendant within two years of death, section 144 of IHTA 1984 treats the appointment as if the deceased had left the property directly to that beneficiary.29 This retrospective treatment preserves RNRB eligibility but requires proactive action within the statutory window. Failure to act within two years is permanent -- there is no late filing mechanism for s.144 appointments.

This provision is particularly important for legacy NRB discretionary trusts. Wills drafted before the 2007 introduction of the TNRB commonly directed assets up to the NRB into a discretionary trust on first death. Where the family home forms part of these assets, the trust defeats both the TNRB (under ss.8A-8C) and the RNRB.30 Accountants reviewing estates where the deceased's will contains an NRB discretionary trust should assess whether a s.144 appointment or a deed of variation under s.142 can restore the RNRB entitlement.

6.3 Cohabiting Couples: A Structural Disadvantage

Unmarried cohabiting couples face a compounded RNRB disadvantage. The surviving partner cannot claim the TRNRB (available only to spouses and civil partners under s.8G). If the deceased's children are from a previous relationship and the couple are not married, the surviving partner's own children from a different relationship do not qualify as "closely inherited" from the deceased.19 The estate is limited to a single RNRB of GBP 175,000 at best, compared to GBP 350,000 for a married couple. Accountants advising cohabiting clients should quantify this differential and present the options, including formalising the relationship where appropriate.

7. The Downsizing Addition: ss.8FA-8FE

7.1 Scope and Conditions

Where a person downsized to a less valuable residence or disposed of their residence entirely on or after 8 July 2015 and died on or after 6 April 2017, the downsizing addition under IHTA 1984 ss.8FA-8FE may reinstate lost RNRB.3132 Six conditions (Conditions A-F) must be satisfied:

  1. The deceased disposed of a qualifying former residential interest (QFRI) on or after 8 July 2015
  2. The QFRI would have qualified for the RNRB if retained in the estate
  3. Direct descendants inherit at least some estate assets (not necessarily the replacement property)
  4. The claim is made within the permitted period
  5. The downsizing addition cannot exceed what RNRB would have been available without the disposal
  6. The addition is limited to the value of closely inherited assets3233

7.2 Worked Example: Five-Step Calculation

Patricia sells her family home (valued at GBP 300,000) in September 2020 and moves into a smaller property (valued at GBP 120,000). She dies in 2026-27 with a total estate of GBP 900,000. The smaller property passes to her son under her will, along with GBP 500,000 of other assets.

Step 1: Available RNRB at the date of disposal (September 2020): GBP 175,000

Step 2: Former home's value as a percentage of Step 1: GBP 300,000 / GBP 175,000 = 171.4%, capped at 100%

Step 3: Current home's value as a percentage of current RNRB maximum: GBP 120,000 / GBP 175,000 = 68.57% (rounded to two decimal places)

Step 4: Lost percentage: 100% - 68.57% = 31.43%

Step 5: Apply Step 4's percentage to the RNRB available at death: 31.43% x GBP 175,000 = GBP 55,000 (the precise unrounded calculation of 120,000/175,000 yields 68.5714%, giving a lost percentage of 31.4286%, which produces exactly GBP 55,000)34

Patricia's total RNRB: GBP 120,000 (from the current property, being the lower of the property value and the available RNRB after applying Step 3) plus the downsizing addition of GBP 55,000 -- subject to confirmation that the total does not exceed the RNRB maximum of GBP 175,000 and that the value of closely inherited assets is sufficient.34

The downsizing addition is subject to the taper in the same way as the main RNRB. Where the estate exceeds GBP 2 million, the total available RNRB (including any downsizing addition) is reduced per IHTM46067.35

7.3 Claims Procedure

The downsizing addition claim is made via form IHT435 (revised April 2025), submitted alongside IHT400.36 Where multiple property disposals occurred, personal representatives must nominate the specific disposal to be taken into account. The claim deadline is 24 months from the end of the month of death. The IHT435 also serves as the claim form for the standard RNRB, so both claims are made on a single form.36

8. Transferable RNRB and Claims Procedure

8.1 The Brought-Forward Allowance

Under section 8G, the unused RNRB from a predeceased spouse or civil partner can be brought forward to the survivor's estate.15 The brought-forward allowance is calculated as a percentage of the maximum RNRB at the first death, applied to the RNRB maximum at the second death -- mirroring the NRB transfer mechanics under ss.8A-8C.37

A critical feature: the first death can have occurred at any date, including before 6 April 2017 when the RNRB did not exist. Where the first death was before that date, the full 100% is available for transfer because no RNRB was used on the first death.37 This is a significant planning benefit for surviving spouses whose partners died years or decades ago.

8.2 Claims Forms and Deadlines

Two distinct forms govern RNRB claims:

  • IHT435 (revised April 2025): Claims the RNRB and downsizing addition for the deceased's own estate36
  • IHT436: Claims the TRNRB from a predeceased spouse or civil partner38

Both forms are filed with IHT400 and must be submitted within 24 months from the end of the month of the survivor's death.39 Accountants administering estates should diarise this deadline at the outset of the administration, particularly for complex estates where the IHT400 filing may be delayed by valuation disputes or missing information.

Conclusion

The RNRB's technical complexity -- confirmed by the OTS and experienced daily by practitioners -- demands a systematic approach to estate administration and planning. Three concurrent developments reshape the planning landscape: pension death benefit inclusion from April 2027, APR/BPR reforms from April 2026, and the continued threshold freeze through at least 2029-30.

For accountants advising clients with estates in the GBP 1.5 million to GBP 2.7 million range, the immediate priorities are clear. Estates approaching the GBP 2 million taper threshold should be modelled with pension values included, quantifying the 60% effective marginal rate within the taper band. Mixed estates containing agricultural or business property require explicit taper estate modelling under IHTM46012, since APR/BPR assets inflate "E" at full value. Lifetime gifts remain the most powerful taper management tool, operating at an effective 60% saving rate within the taper band. The downsizing addition under ss.8FA-8FE should be assessed for every estate where the deceased changed property on or after 8 July 2015. Trust structures in existing wills -- particularly legacy NRB discretionary trusts -- should be reviewed against the "closely inherited" requirements, with the two-year s.144 window diarised for post-death remedial action. Correct and timely filing of IHT435 and IHT436, within the 24-month deadline, completes the procedural framework.

The RNRB is not a simple relief, and practitioners who treat it as such risk material losses for their clients. Mastery of its calculation mechanics, taper interactions, and procedural requirements remains a core professional competency for any accountant engaged in estate planning and administration.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Inheritance tax, estate administration, residential property tax, trust taxation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Calculate the available RNRB after applying the taper reduction for estates exceeding GBP 2 million, including quantification of the 60% effective marginal rate within the taper band
  2. Evaluate the impact of pension death benefit inclusion from April 2027 on the RNRB taper threshold for estates in the GBP 1.5-2.5 million range
  3. Apply the five-step downsizing addition calculation under ss.8FA-8FE for estates where the deceased disposed of a qualifying residential interest on or after 8 July 2015
  4. Distinguish between trust structures that preserve the RNRB (IPDI, bereaved minor, disabled person's) and those that defeat it (discretionary), including the s.144 remedial mechanism
  5. Analyse the interaction between APR/BPR assets and the RNRB taper estate value "E" per IHTM46012, and identify planning strategies to mitigate taper exposure in mixed estates

Competency Mapping

  • ICAEW Technical Competency: Tax compliance and advisory services -- inheritance tax
  • ATT/CTA Competency: Inheritance tax planning and estate administration
  • AAT Professional Ethics: Professional competence and due care in tax advisory work

Reflective Questions

  1. How would the inclusion of pension death benefits from April 2027 affect the RNRB taper exposure of estates currently under administration or active planning?
  2. What additional modelling steps should be incorporated into estate planning processes for clients holding both residential property and agricultural or business assets qualifying for APR/BPR?
  3. Are existing will structures within the client base -- particularly those containing NRB discretionary trusts drafted before 2007 -- being systematically reviewed for RNRB compatibility?

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. OTS -- Simplifying the design of Inheritance Tax (July 2019). https://www.gov.uk/government/publications/ots-inheritance-tax-review-simplifying-the-design-of-the-tax ↩ ↩2

  2. HMRC monthly bulletin -- IHT receipts (February 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩ ↩2

  3. Finance Act 2025, Part 3 -- Inheritance tax. https://www.legislation.gov.uk/ukpga/2025/8/part/3/crossheading/inheritance-tax ↩ ↩2

  4. IHTM46012 -- Value of estate "E" and "VT". https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46012 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  5. GOV.UK -- Agricultural property relief and business property relief changes. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4 ↩5

  6. Finance (No. 2) Act 2015, s.9. https://www.legislation.gov.uk/ukpga/2015/33/part/2/crossheading/rate-bands ↩

  7. IHTM46001 -- Residence nil-rate band: general overview. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46001 ↩

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

  9. 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

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

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

  12. IHTA 1984, s.8D. https://www.legislation.gov.uk/ukpga/1984/51/section/8D ↩ ↩2

  13. IHTA 1984, s.8E. https://www.legislation.gov.uk/ukpga/1984/51/section/8E ↩

  14. IHTA 1984, s.8F. https://www.legislation.gov.uk/ukpga/1984/51/section/8F ↩

  15. IHTA 1984, s.8G. https://www.legislation.gov.uk/ukpga/1984/51/section/8G ↩ ↩2

  16. IHTA 1984, s.8H. https://www.legislation.gov.uk/ukpga/1984/51/section/8H ↩

  17. IHTM46011 -- Qualifying residential interest. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46011 ↩

  18. IHTM46032 -- Residence outside the UK. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46032 ↩

  19. IHTA 1984, s.8K. https://www.legislation.gov.uk/ukpga/1984/51/section/8K ↩ ↩2 ↩3

  20. IHTM46013 -- Closely inherited. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46013 ↩ ↩2 ↩3

  21. IHTM46014 -- Inherited. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46014 ↩

  22. IHTM46023 -- Taper threshold. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46023 ↩ ↩2 ↩3 ↩4

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

  24. Burges Salmon -- Smaller farms, IHT, and the RNRB. https://www.burges-salmon.com/articles/102jpaa/smaller-farms-inheritance-tax-the-3m-claim-and-the-residence-nil-rate-band/ ↩

  25. Standard Life Adviser -- Pensions and IHT from April 2027. https://www.standardlife.co.uk/adviser/business-support/insight-opinion/article-page/pensions-and-inheritance-tax-from-april-2027 ↩ ↩2

  26. Royal London for Advisers -- IHT on pension death benefits from April 2027. https://adviser.royallondon.com/technical-central/pensions/death-benefits/inheritance-tax-on-pension-death-benefits-from-april-2027/ ↩

  27. IHTM46013 -- Closely inherited and trust treatment. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46013 ↩ ↩2 ↩3

  28. GOV.UK -- Check if estate qualifies for RNRB. https://www.gov.uk/guidance/check-if-you-can-get-an-additional-inheritance-tax-threshold ↩ ↩2

  29. IHTA 1984, s.144. https://www.legislation.gov.uk/ukpga/1984/51/section/144 ↩

  30. IHTM43016 -- Unconstituted NRB trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43016 ↩

  31. IHTA 1984, s.8FA. https://www.legislation.gov.uk/ukpga/1984/51/section/8FA ↩

  32. IHTM46050 -- Downsizing general principles. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46050 ↩ ↩2

  33. IHTM46060 -- Downsizing calculations overview. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46060 ↩

  34. GOV.UK -- How downsizing affects the RNRB. https://www.gov.uk/guidance/how-downsizing-selling-or-gifting-a-home-affects-the-additional-inheritance-tax-threshold ↩ ↩2

  35. IHTM46067 -- Downsizing interaction with taper. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46067 ↩

  36. IHT435 form (revised April 2025). https://assets.publishing.service.gov.uk/media/67ee9503e9c76fa33048c768/claim-for-residence-nil-rate-band-iht435.pdf ↩ ↩2 ↩3

  37. IHTM46040 -- Brought-forward allowance. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46040 ↩ ↩2

  38. IHT436 -- Claim to transfer unused RNRB. https://www.gov.uk/government/publications/claim-to-transfer-any-unused-residence-nil-rate-band-iht436 ↩

  39. IHTM46042 -- When and how claims are made. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46042 ↩

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