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Tax Planning Amid Global Instability: IHT Strategies for Volatile Assets and Economies

· 21 min

Executive Summary

Inheritance tax is a point-in-time levy: the IHTA 1984 s.160 open market value test applies at the date of death, regardless of subsequent market movements. In an environment of stretched asset valuations, trade tariff uncertainty, and OECD-projected UK GDP growth of 1.2% for 2026, this produces material divergence between date-of-death IHT liabilities and the realisable value of estate assets. IHT receipts reached GBP 7.1 billion in the first ten months of 2025-26, with frozen thresholds compounding fiscal drag. Three converging reforms -- the APR/BPR relief cap from April 2026, BPR reduction on AIM shares to 50%, and pension death benefits entering the IHT charge from April 2027 -- amplify volatility exposure. This article provides a framework for tax advisors: exploiting loss-on-sale reliefs for shares and land, timing lifetime gifts during market troughs, managing instalment options, and addressing the gap where cryptoassets receive no equivalent relief.

1. The Volatility Context: Why Market Conditions Matter for Inheritance Tax

Inheritance tax planning has traditionally been framed as a static exercise: identify the estate, apply reliefs, calculate the liability. The current economic environment demands a fundamentally different approach. The OECD projects UK GDP growth easing to 1.2% in 2026 amid trade tariff uncertainty, while the EY ITEM Club forecasts 0.9%.1 The Bank of England's December 2025 Financial Stability Report identifies risky asset valuations as "materially stretched," with UK equity valuations at their most stretched since the global financial crisis.2 Concurrently, 51% of respondents to the Bank's Systemic Risk Survey rate the probability of a high-impact market event as "medium," a 9 percentage point increase from the previous survey.3

These macroeconomic conditions interact directly with the IHT framework. IHT receipts reached GBP 7.1 billion in the period April 2025 to January 2026, GBP 0.1 billion higher year-on-year, with the OBR Spring Statement forecast projecting GBP 9.1 billion for the full year.4 The nil-rate band remains frozen at GBP 325,000 and the residence nil-rate band at GBP 175,000 through 2030-31, creating fiscal drag that draws more estates into the IHT charge as nominal asset values fluctuate above static thresholds.5 CPI inflation stood at 3.0% in January 2026 -- above the Bank of England's 2% target -- compounding this effect, as nominal values may rise while real purchasing power stagnates.16

The core tension is structural. Section 160 of the IHTA 1984 values property at "the price which the property might reasonably be expected to fetch if sold in the open market at that time," with the relevant time being immediately before death per s.4(1).7 The statute does not permit adjustment for subsequent market movements, distressed sale conditions, or illiquidity discounts beyond those reflected in the open market value at the relevant date. Where estate assets decline materially in value between death and realisation, the estate pays IHT on a value it can no longer recover -- unless specific statutory reliefs are claimed.

Three converging reforms amplify this volatility exposure. The APR/BPR relief provisions contained in the Finance (No. 2) Bill 2024-26, which completed Public Bill Committee stage on 3 February 2026 and awaits Report Stage scheduling, provide for a combined 100% relief allowance capped at GBP 2.5 million from 6 April 2026, with 50% relief applying thereafter.8 BPR on AIM shares reduces from 100% to 50%, creating an effective 20% IHT rate where previously no tax was payable.9 From 6 April 2027, unused pension funds and death benefits enter the estate for IHT purposes, adding a further volatile asset class with no loss-on-sale relief mechanism.10 These reforms coincide with the residence-based IHT regime enacted from 6 April 2025, which replaced the domicile-based system and introduced a 10-of-20-year long-term resident test with tail provisions of 3 to 10 years after departure.8 Tax advisors who fail to integrate volatility awareness into IHT planning risk both over-taxation of client estates and under-utilisation of available reliefs.

2. Date-of-Death Valuation and Market Timing Risk

The Section 160 Framework

The s.160 open market value test constructs a hypothetical transaction between a willing buyer and willing seller at the date of death.7 HMRC guidance at IHTM09703 confirms that the valuation assumes neither party is under compulsion to transact, and that the property has been exposed to the market for a reasonable period before the valuation date.11 The HMRC Inheritance Tax Toolkit identifies valuations as "the biggest single area of risk" in IHT compliance.12

In volatile markets, this framework produces three categories of risk. First, the date-of-death value may significantly exceed the value realisable by the time personal representatives obtain the grant of probate and are in a position to sell assets. Second, the hypothetical willing buyer/willing seller construct assumes orderly market conditions that may not reflect a dislocated or distressed market. Third, the statutory instruction that the price "shall not be assumed to be reduced on the ground that the whole property is to be placed on the market at one and the same time" prevents the type of bulk-sale discount that estates with concentrated positions would face in practice.7

Share Valuation Mechanics

For listed shares, the IHT valuation applies the quarter-up method: the lower of the two prices shown in the Stock Exchange Daily Official List, plus one-quarter of the difference between them.13 This methodology provides a precise, verifiable valuation anchored to market data at the date of death. For thinly traded AIM shares, however, HMRC may not accept published prices as reflecting tax market value, requiring alternative valuation approaches that introduce scope for dispute.13

From April 2026, the BPR cap at GBP 2.5 million means more unquoted share valuations will be negotiated with HMRC's Shares and Assets Valuation team, as the quantum of relief at stake rises materially.14 Valuation disputes for unquoted shares can take years to resolve, particularly where discount rates, comparable transactions, and methodology selection are contested. In volatile markets, the gap between the parties' positions may widen, prolonging disputes and increasing advisory costs. Robust contemporaneous valuation evidence -- including independent valuations, market comparables, and documented methodology -- is essential.

Property Valuations and Regional Divergence

UK house prices increased 2.4% in the 12 months to December 2025 on a national basis, but this aggregate figure masks significant regional divergence: the North East recorded 4.6% growth while London experienced a 1.0% decline.15 A monthly decline of 0.2% between November and December 2025 on a seasonally adjusted basis indicates market softening. With 6% more homes for sale than a year ago, increased supply may moderate price growth further in 2026.15 For estates with substantial residential property, these divergent trends create estate-specific volatility exposure that advisors must assess on a case-by-case basis, with particular attention to whether regional trends are likely to generate loss-on-sale relief eligibility within the qualifying period under ss.190-198.

3. Loss on Sale of Shares Relief: The Primary Post-Death Tool

Statutory Framework

Sections 178-189 of the IHTA 1984 provide that where qualifying investments are sold within 12 months of death for less than their date-of-death value, the aggregate sale value may be substituted for the aggregate date-of-death value on a claim by the appropriate person.1617

Qualifying investments under s.178 include shares or securities quoted on a recognised stock exchange at the date of death, holdings in authorised unit trusts, shares in open-ended investment companies, AIM-listed shares, and UK government stock (gilts).16 Critically, this is an aggregate test: all qualifying investments sold within the 12-month window are combined into a single calculation. Profitable sales offset losing sales, so the claim is beneficial only where the aggregate of all sales shows a net loss against the aggregate of all date-of-death values.

Anti-Avoidance Restrictions

Section 180 imposes a proportional reduction where the appropriate person purchases qualifying investments in the same capacity within the period from the date of death to two months after the last qualifying sale.18 This restriction prevents personal representatives from selling depressed assets to claim loss-on-sale relief and simultaneously reinvesting in replacement securities. The proportional reduction is calculated as the ratio of purchase prices to sale values, applied to the gross relief otherwise available. Advisors must ensure that any purchases during the qualifying period are factored into the relief calculation and that personal representatives are warned against portfolio reinvestment during the restriction window.

Worked Example: Listed Portfolio

Consider an estate containing a listed equity portfolio valued at GBP 500,000 at death. Over the following six months, the portfolio declines by 15%, and personal representatives sell all holdings for an aggregate GBP 425,000. The aggregate loss is GBP 75,000. Substituting the sale value reduces the estate value by GBP 75,000, saving GBP 30,000 in IHT at the 40% rate. The claim is made on Form IHT35 within the statutory time limit.19

Had the personal representatives sold only the losing positions (aggregate loss GBP 100,000) and retained profitable holdings (aggregate gain GBP 25,000), the aggregate calculation would still apply to all qualifying investments sold. Selective selling of losing positions while retaining gainers maximises the relief, provided the retained positions are not sold within the 12-month window. This requires active portfolio management by the personal representatives -- a point that demands early discussion with beneficiaries and careful diary management of the 12-month anniversary.

The Instalment/Loss-on-Sale Tension

A critical interaction arises where qualifying property is also eligible for the instalment option under ss.227-228. Selling shares to crystallise loss-on-sale relief terminates the instalment option for that property, with all outstanding instalments becoming immediately payable under s.227(4).20 Advisors must weigh the relief quantum against the liquidity benefit of retaining the instalment arrangement, particularly for volatile AIM portfolios where the interest-free instalment option is extended from April 2026. The decision framework requires comparing the net present value of the immediate IHT saving against the cash-flow benefit of deferred instalments, factoring in opportunity costs and the estate's broader liquidity position.

4. Loss on Sale of Land Relief and the Property Market

Statutory Framework

Sections 190-198 of the IHTA 1984 provide a parallel relief for interests in land. Under s.191(1), the primary qualifying period is three years immediately following the date of death.2122 Section 197A provides an extended provision for certain fourth-year sales, but this extension is subject to restrictions and does not apply where compulsory acquisition provisions under s.197(1) are in effect.22 HMRC guidance at IHTM33011 uses "within four years of the death" as a shorthand description, but the primary statutory period is three years, with fourth-year sales qualifying only in the restricted circumstances set out in s.197A.23 The relief applies on an aggregate basis across all land interests sold, operates through Form IHT38, and is subject to a proportional restriction under s.192 IHTA 1984 where the appropriate person purchases land or buildings within the period from death to four months after the final qualifying sale.24

The three-to-four-year qualifying window distinguishes land relief from the 12-month share relief window, reflecting the longer disposition timelines typical of property transactions. This extended period is particularly relevant in the current market, where regional divergence creates estate-specific outcomes: a London estate with residential property may be eligible for land loss relief given the city's 1.0% price decline, while a North East estate may not.15

Practical Application

Consider a London residential property valued at GBP 1.2 million at death. Eighteen months later, the property sells for GBP 1.128 million, reflecting a 6% decline consistent with London market trends. The GBP 72,000 reduction substitutes into the estate value, saving GBP 28,800 in IHT at the 40% rate. This loss exceeds both s.191(2) de minimis thresholds: it is greater than GBP 1,000 in absolute terms and greater than 5% of the GBP 1.2 million death value (GBP 60,000).21 Where the estate also contains a commercial property that appreciated in value and was sold within the qualifying period under ss.190-198, the appreciation offsets the residential loss in the aggregate calculation, potentially eliminating or reducing the net relief available.

Personal representatives should consider the timing of land dispositions strategically: where the estate holds multiple land interests and some have appreciated, delaying sales of appreciating properties beyond the qualifying period (if commercially feasible) may preserve the aggregate loss-on-sale relief for depreciating properties. This interaction between the aggregate calculation and the timing of individual dispositions requires co-ordinated estate administration that many practitioners do not instinctively consider.

5. The Cryptoasset Gap and Emerging Volatile Assets

IHT Treatment

HMRC confirms at CRYPTO25000 that cryptoassets are "property for the purposes of Inheritance Tax."25 Under the residence-based IHT regime enacted from 6 April 2025, worldwide cryptoassets of long-term UK residents fall within the IHT charge regardless of where they are held.25 No statutory situs rules exist for cryptoassets; situs determination for non-long-term residents relies on general property law principles, introducing further uncertainty for cross-border estates.

The Relief Gap

Cryptoassets do not constitute qualifying investments under s.178 (they are neither shares nor securities quoted on a recognised stock exchange, nor units in authorised unit trusts, nor OEIC shares). Nor are they interests in land under ss.190-198. This produces a material gap: estates with volatile digital asset holdings cannot access either loss-on-sale relief regime.2526

The practical consequence is significant. A Bitcoin portfolio valued at GBP 200,000 at the date of death that declines to GBP 100,000 by the time of realisation generates no IHT adjustment. The estate pays GBP 80,000 in IHT (at 40%) on the date-of-death value, despite receiving only GBP 100,000 on sale. An equivalent equity portfolio declining by the same amount would generate GBP 40,000 of IHT savings through loss-on-sale relief. This disparity creates a GBP 40,000 differential in tax treatment for identical economic outcomes, arising solely from the asset classification.

Reporting and Compliance

From 1 January 2026, UK crypto platforms report transaction data to HMRC under the Crypto-Asset Reporting Framework.27 This increased visibility means HMRC can cross-reference CARF data with IHT accounts, making accurate reporting of cryptoasset holdings at death essential. Advisors should ensure estates maintain contemporaneous valuation evidence -- typically screenshots of exchange prices at the date of death and documentation of the methodology used to determine open market value. Unlike listed shares, where the quarter-up method provides a standardised approach, no equivalent HMRC-endorsed valuation methodology exists for cryptoassets, introducing both compliance risk and scope for professional judgement.

Mitigation Strategies

In the absence of loss-on-sale relief, practitioners may consider whether a deed of variation under s.142 IHTA 1984 could redirect volatile cryptoassets to an IHT-exempt beneficiary (such as a spouse or charity), removing them from the taxable estate within two years of death. Alternatively, lifetime transfers of cryptoassets during market troughs exploit the PET framework at depressed values, though this requires the donor to survive seven years for the transfer to fall outside the estate entirely. The capital gains tax interaction also warrants consideration: a lifetime gift is a disposal at market value for CGT purposes, and transferring during a trough may reduce or eliminate the CGT charge as well as the IHT value transferred.

6. AIM Shares at the Business Property Relief Inflection Point

The Fundamental Shift

Until 5 April 2026, AIM-listed shares meeting the two-year holding requirement qualify for 100% BPR under s.105(1)(cc) IHTA 1984, provided the trading condition is satisfied.8 At 100% relief, valuation volatility is IHT-irrelevant: the relief eliminates the tax regardless of the share price at death.

From 6 April 2026, this changes fundamentally. BPR on AIM shares reduces to 50%, creating an effective IHT rate of 20% on qualifying AIM holdings.9 The GBP 2.5 million combined APR/BPR 100% relief allowance does not extend to AIM shares -- they receive only 50% relief regardless of value.8 For the first time, AIM share price fluctuations translate directly into IHT consequences.

Worked Example: AIM Portfolio Volatility

Consider an estate with an AIM portfolio valued at GBP 1 million at death (after 6 April 2026). BPR at 50% reduces the taxable value to GBP 500,000, generating IHT of GBP 200,000 at the 40% rate. If the AIM portfolio declines by 25% to GBP 750,000 within six months of death, selling the entire portfolio triggers loss-on-sale relief under ss.178-189: the aggregate date-of-death value of GBP 1 million is replaced by the aggregate sale value of GBP 750,000. BPR at 50% reduces the taxable value to GBP 375,000, producing IHT of GBP 150,000 -- a saving of GBP 50,000.

However, claiming loss-on-sale relief requires selling the shares, which terminates the interest-free instalment option extended to all BPR-qualifying property from April 2026.28 If the personal representatives had retained the instalment option, the GBP 200,000 IHT liability would be spread over 10 annual interest-free instalments of GBP 20,000 each. The decision therefore requires comparing the GBP 50,000 immediate tax saving against the cash-flow benefit of GBP 180,000 deferred over nine years. Where the personal representatives expect the AIM portfolio to recover, retaining both the shares and the instalment option may be preferable.

7. Lifetime Gifts: Exploiting Market Troughs

The Strategic Opportunity

The IHTA 1984 s.3A PET framework values gifts at the date of transfer.29 In volatile markets, timing a gift during a market trough reduces the value transferred for IHT purposes. If the donor survives seven years, the gift falls out of the estate entirely, and any subsequent appreciation accrues to the recipient free of IHT. This asymmetry -- transferring at a depressed value while preserving the potential for recovery -- makes market downturns a strategic opportunity for proactive estate planning rather than merely a risk to be managed.

Fall-in-Value Relief as a Safety Net

Where the donor dies within seven years of a PET or CLT and the transferred property has fallen in value between the date of transfer and the date of death (or earlier qualifying sale), fall-in-value relief under ss.131-140 reduces the additional tax payable.3031 This statutory safety net operates symmetrically with the market-trough gifting strategy: if values fall further after the gift, the relief limits the tax charge; if values recover, the gift was made at the lower value with no adverse consequence.

The conditions under s.131(1) require that the tax or additional tax is payable because of the transferor's death within seven years, that the value transferred is attributable to the property, that the property is still held by the transferee (or spouse) at the date of death or has been sold in a qualifying sale, and that the market value at the relevant date is less than the value at the date of transfer.31

Taper Relief Interaction

Where the donor dies between three and seven years after the gift, taper relief reduces the IHT payable: 20% reduction for deaths in years 3-4, 40% in years 4-5, 60% in years 5-6, and 80% in years 6-7.32 Taper relief applies only to reduce the tax below its normal amount and does not generate a refund. The interaction with fall-in-value relief means that a gift made during a market trough carries dual protection: fall-in-value relief if the asset declines further, and taper relief providing progressive reduction if the donor survives beyond three years. Practitioners advising clients on the timing of significant lifetime transfers should model both scenarios -- recovery and further decline -- to demonstrate the risk-adjusted outcome under each pathway.

8. Instalment Payments and Liquidity Management

IHT on qualifying property may be paid in 10 equal annual instalments under ss.227-228 IHTA 1984.33 Qualifying property includes land, business interests, and shares or securities giving control of the company. Instalments on land and controlling shareholdings in unquoted companies are interest-free under s.234, provided each instalment is paid on time.34

From April 2026, the interest-free instalment option extends to all property qualifying for APR or BPR, including AIM shares.28 This development is significant for volatile estates: personal representatives can spread IHT payments over 10 years while retaining the option to sell assets at more favourable market conditions, avoiding distressed sales that crystallise losses.

The strategic decision framework requires advisors to assess whether the estate should prioritise the instalment option (retaining volatile assets in anticipation of recovery) or claim loss-on-sale relief (selling within the qualifying window to substitute lower values). This decision depends on the expected direction and magnitude of asset price movements, the estate's liquidity position, the beneficiaries' time horizon, and the relative quantum of the tax saving from loss-on-sale relief versus the cash-flow benefit of instalment payment. Where estates contain both instalment-qualifying and non-qualifying assets, advisors should consider whether non-qualifying liquid assets can fund the immediate IHT liability while instalment-qualifying assets are retained.

9. Convergence Planning: APR/BPR, Pensions, and Volatility

The APR/BPR cap at GBP 2.5 million from April 2026 introduces valuation sensitivity for border-case estates.8 Where combined qualifying assets fluctuate around the threshold, the difference between 100% relief and 50% relief on the marginal pound produces a 20% swing in effective IHT rate. In volatile markets, whether an estate benefits from the full allowance may depend on the date of death relative to market conditions -- a timing factor entirely outside the individual's control.

From April 2027, unused pension funds and death benefits enter the estate for IHT purposes, with personal representatives (not scheme administrators) liable for reporting and payment.10 Defined contribution pension pots invested in equities, property funds, or multi-asset strategies will be subject to the same valuation timing risk as other volatile assets. Critically, pension assets do not qualify as either "qualifying investments" under s.178 or "interests in land" under s.190, meaning no loss-on-sale relief will be available for pension assets that decline between the date of death and the settlement of the estate. Approximately 10,500 estates are projected to incur a new IHT liability as a result.10

The combined effect for a complex estate -- containing business assets near the GBP 2.5 million cap, an AIM portfolio at 50% BPR, a DC pension pot, and cryptoasset holdings -- is multiple points of volatility exposure with inconsistent relief availability. Practitioners should implement systematic monitoring of client asset values relative to key thresholds, maintain contemporaneous valuation evidence across all asset classes, and develop proactive lifetime gifting programmes that exploit market troughs while statutory windows remain available.

Conclusion

Economic instability and asset price volatility are not background risks for IHT planning -- they are material variables that directly affect estate valuations, the availability of statutory reliefs, and the quantum of tax payable. The statutory framework provides a toolkit of responses: loss on sale of shares relief (ss.178-189) for equity portfolios within a 12-month window, loss on sale of land relief (ss.190-198) within a three-to-four-year qualifying window, fall-in-value relief (ss.131-140) for lifetime gifts, and the instalment option (ss.227-228) for liquidity management. Each mechanism carries specific conditions, aggregate calculations, and anti-avoidance restrictions that require careful navigation.

Equally significant are the gaps. Cryptoassets and, from April 2027, pension assets receive no loss-on-sale relief, creating a punitive outcome for estates holding volatile digital or retirement assets. The reduction of AIM BPR from 100% to 50% from April 2026 introduces IHT sensitivity to a market segment characterised by inherent price volatility. Tax advisors who understand these interactions -- and who build volatility awareness into their advisory frameworks -- will be better positioned to discharge their professional duty of care in an era of economic uncertainty.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Inheritance Tax, Estate Administration, Investment Tax Planning, Private Client Advisory

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the statutory mechanisms available for managing IHT liability on volatile assets, including loss on sale of shares (ss.178-189), loss on sale of land (ss.190-198), fall-in-value relief (ss.131-140), and the instalment option (ss.227-228)
  2. Calculate the loss on sale of shares relief quantum for a mixed equity portfolio using the aggregate methodology, applying the s.180 anti-avoidance restriction for qualifying purchases
  3. Evaluate the interaction between the instalment payment option and loss-on-sale relief, determining when to prioritise instalment retention versus claim submission for estates holding volatile qualifying property
  4. Assess the IHT implications of the cryptoasset loss-on-sale relief gap for estates with significant digital asset holdings, identifying alternative mitigation strategies
  5. Analyse how the reduction of BPR on AIM shares from 100% to 50% from April 2026 changes the volatility risk profile of AIM-based IHT planning

Competency Mapping

  • CIOT/ATT: Inheritance Tax -- reliefs and exemptions; estate administration; lifetime transfers
  • ICAEW: Tax compliance and advisory -- IHT planning, volatile asset valuation, post-death relief mechanisms
  • SRA Competency B: Technical legal knowledge -- tax law affecting estate administration

Reflective Questions

  1. How would the loss-on-sale relief aggregate calculation affect the administration strategy for estates with mixed equity portfolios containing both gaining and losing positions?
  2. What additional documentation and monitoring procedures should be implemented for clients with cryptoasset holdings, given the absence of loss-on-sale relief for digital assets?
  3. How might the extension of the interest-free instalment option to AIM shares from April 2026 change the advice given to personal representatives managing volatile AIM portfolios?

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. OECD, Economic Outlook Volume 2025 Issue 2 -- United Kingdom. https://www.oecd.org/en/publications/2025/12/oecd-economic-outlook-volume-2025-issue-2_413f7d0a/full-report/united-kingdom_9fc28efb.html; EY, Trade uncertainty set to weigh on UK growth over the next two years. https://www.ey.com/en_uk/newsroom/2025/04/trade-disruption-limits-uk-growth ↩ ↩2

  2. Bank of England, Financial Stability Report -- December 2025. https://www.bankofengland.co.uk/financial-stability-report/2025/december-2025 ↩

  3. Bank of England, Systemic Risk Survey Results -- 2025 H2. https://www.bankofengland.co.uk/systemic-risk-survey/2025/2025-h2 ↩

  4. HMRC Tax Receipts and National Insurance Contributions for the UK (monthly bulletin, 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; OBR, Inheritance Tax Forecast. https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

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

  6. ONS, Consumer price inflation, UK: January 2026. https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/consumerpriceinflation/january2026 ↩

  7. Inheritance Tax Act 1984, section 160. https://www.legislation.gov.uk/ukpga/1984/51/section/160 ↩ ↩2 ↩3

  8. 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

  9. Rathbones, Business Property Relief and AIM: the latest changes and what they mean for inheritance tax planning. https://www.rathbones.com/en-gb/wealth-management/knowledge-and-insight/business-property-relief-and-aim-changes-inheritance-tax-planning ↩ ↩2

  10. GOV.UK, Inheritance Tax on 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

  11. HMRC Inheritance Tax Manual, IHTM09703 -- Valuation: open market value. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm09703 ↩

  12. HMRC Inheritance Tax Toolkit. https://assets.publishing.service.gov.uk/media/5b2a130340f0b634babc0559/IHT-toolkit.pdf ↩

  13. HMRC Inheritance Tax Manual, IHTM18093 -- Stocks and shares: valuation: shares. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm18093 ↩ ↩2

  14. KPMG, Inheritance Tax: Managing BPR share valuation risk. https://kpmg.com/uk/en/insights/tax/tmd-inheritance-tax-managing-bpr-share-valuation-risk.html ↩

  15. GOV.UK, UK House Price Index for December 2025. https://www.gov.uk/government/news/uk-house-price-index-for-december-2025 ↩ ↩2 ↩3

  16. Inheritance Tax Act 1984, section 178. https://www.legislation.gov.uk/ukpga/1984/51/section/178 ↩ ↩2

  17. HMRC Inheritance Tax Manual, IHTM34010 -- Loss on sale of shares: background. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm34010 ↩

  18. HMRC Inheritance Tax Manual, IHTM34212 -- Restrictions on relief for purchases: the restriction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm34212 ↩

  19. GOV.UK, Inheritance Tax: claim for relief -- loss on sale of shares (IHT35). https://assets.publishing.service.gov.uk/media/636b8e51e90e076193991003/Form_IHT35_-_Claim_for_relief_-_loss_on_sale_of_shares.pdf ↩

  20. HMRC Inheritance Tax Manual, IHTM30322 -- End of instalment option: meaning of 'sold'. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm30322 ↩

  21. Inheritance Tax Act 1984, section 191. https://www.legislation.gov.uk/ukpga/1984/51/section/191 ↩ ↩2

  22. Inheritance Tax Act 1984, section 197A. https://www.legislation.gov.uk/ukpga/1984/51/section/197A ↩ ↩2

  23. HMRC Inheritance Tax Manual, IHTM33011 -- Loss on sale of land: outline of the relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm33011 ↩

  24. Inheritance Tax Act 1984, section 192. https://www.legislation.gov.uk/ukpga/1984/51/section/192 ↩

  25. HMRC Cryptoassets Manual, CRYPTO25000 -- Cryptoassets for individuals: Inheritance Tax. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto25000 ↩ ↩2 ↩3

  26. Farrer & Co, Tips for executors of an estate containing cryptoassets. https://www.farrer.co.uk/news-and-insights/tips-for-executors-of-an-estate-containing-cryptoassets/ ↩

  27. GOV.UK, The Crypto-Asset Reporting Framework and amendments to the Common Reporting Standard. https://www.gov.uk/government/publications/the-crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard; BDO, New rules in 2026 will make it harder for crypto investors to evade tax. https://www.bdo.co.uk/en-gb/news/2025/new-rules-in-2026-will-make-it-harder-for-crypto-investors-to-evade-tax ↩

  28. GOV.UK, Agricultural property relief and business property relief changes -- instalment option. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2

  29. HMRC Inheritance Tax Manual, IHTM14001 -- Lifetime transfers: introduction to lifetime transfers. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14001 ↩

  30. HMRC Inheritance Tax Manual, IHTM14621 -- Fall in value relief: introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14621 ↩

  31. Inheritance Tax Act 1984, section 131. https://www.legislation.gov.uk/ukpga/1984/51/section/131 ↩ ↩2

  32. HMRC Inheritance Tax Manual, IHTM14611 -- Lifetime transfers: taper relief: when the relief applies. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14611 ↩

  33. HMRC Inheritance Tax Manual, IHTM30191 -- Instalment option: introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm30191 ↩

  34. HMRC Inheritance Tax Manual, IHTM30363 -- Interest period: instalments with interest relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm30363 ↩

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