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Transfer of Unused Nil-Rate Band: Practical Application and Common Errors

· 20 min

Executive Summary

The transferable nil-rate band under IHTA 1984 ss.8A-8C can double the tax-free threshold to GBP 650,000, yet practitioner errors in its application remain pervasive and costly. With the NRB frozen at GBP 325,000 through at least 2029-30, IHT receipts reaching GBP 7.1 billion in the first ten months of 2025-26, and HMRC investigations surging 33% over three years, the financial and regulatory consequences of TNRB miscalculation are intensifying.12 Three concurrent developments compound the risk: the residence-based IHT regime from April 2025 altering VT calculations, pension death benefit inclusion from April 2027 elevating RNRB taper exposure, and APR/BPR allowance restructuring from April 2026 creating a third transferable allowance.34 This article provides a systematic error-taxonomy framework covering eight identifiable error categories, each with diagnostic criteria, worked corrections, and HMRC cross-references that practitioners can apply immediately to current casework.

1. Introduction: Why TNRB Errors Matter Now

The nil-rate band has been frozen at GBP 325,000 since 6 April 2009. Finance Act 2025 extended this freeze through 2029-30, with the October 2025 Budget announcing a further extension to 2030-31 to be legislated via Finance Bill 2025-26.56 This prolonged fiscal drag means the TNRB's value in real terms grows with each passing year. A successful full claim saves up to GBP 130,000 in IHT at the 40% rate; an unsuccessful or incorrectly computed claim forfeits that saving partially or entirely.

The fiscal context underscores the stakes. HMRC data for 2022-23 confirms 31,500 estates incurred IHT charges -- 4.62% of UK deaths -- with total liabilities of GBP 6.70 billion, up 12% on 2021-22.7 The average IHT charge per estate stands at approximately GBP 212,000, with an average effective rate of 13% against the 40% headline rate -- a disparity that reflects the widespread use of reliefs and exemptions, including TNRB, in reducing the final liability.7 The OBR forecasts receipts of GBP 8.7 billion for 2025-26, with projections reaching GBP 14.5 billion by 2030-31.8

Concurrently, HMRC's compliance activity has intensified. Data obtained through freedom of information requests indicates that 14,027 families faced IHT investigations between April 2022 and December 2025, with new investigations rising 33% over three years to approximately 4,200 in 2024-25.2 HMRC's deployment of data-matching tools, AI-driven risk assessment, Land Registry cross-referencing, and Trust Registration Service records means that computational and documentation errors that might previously have escaped scrutiny face significantly elevated detection risk. HMRC retains the power to investigate estate valuations for up to 20 years in cases of deliberate behaviour, with shorter windows of 4 years for innocent errors and 6 years for careless behaviour, as provided by the Taxes Management Act 1970 ss.34 and 36 as applied to IHT.9

Against this backdrop, three legislative developments create new TNRB error vectors. The residence-based IHT regime from 6 April 2025 replaces domicile with long-term UK residence as the connecting factor, directly altering VT calculations for non-UK-resident first spouses.3 The confirmed inclusion of pension death benefits in the IHT estate from 6 April 2027 will push more estates above the GBP 2 million RNRB taper threshold, making correct TNRB claims critical to preserving RNRB entitlement.10 The restructuring of APR/BPR relief from April 2026 -- with 100% relief capped at GBP 2.5 million per individual and the allowance transferable between spouses -- creates a third transferable allowance that practitioners must coordinate alongside NRB and RNRB.4

This article does not replicate the comprehensive technical guide to TNRB mechanics; rather, it is structured around the errors practitioners make, providing a diagnostic framework organised by error category with worked corrections and HMRC cross-references.

2. The TNRB Mechanism: A Concise Foundation

Finance Act 2008, s.10, Schedule 4, paragraph 2 inserted sections 8A, 8B, and 8C into IHTA 1984, establishing the transferable nil-rate band for surviving spouses or civil partners dying on or after 9 October 2007.1112 The first death can have occurred at any date, including under Estate Duty or Capital Transfer Tax.

Three features of the mechanism are essential context for the error categories that follow:

The percentage basis. Section 8A(4) prescribes the formula: (E / NRBMD) x 100, where E is the unused NRB at first death and NRBMD is the NRB maximum at first death. The resulting percentage, calculated to four decimal places per IHTM43020, is then applied to the NRB at the survivor's death -- not the NRB at the first death.13 This is a percentage transfer, not a monetary transfer.

The claim requirement. TNRB is not automatic. Section 8B requires a formal claim by the survivor's personal representatives via form IHT402 (with IHT400) or IHT217 for excepted estates.1415 The permitted period is 24 months from the end of the month of the survivor's death, or 3 months from the date the personal representatives first acted, whichever is later.16

The 100% cap. Section 8A(5) limits the aggregate transferable percentage from one or more predeceased spouses to 100% of the NRB at the survivor's death.17 Excess percentages are wasted.

3. Error Category 1: The Fixed-Amount Fallacy

The most fundamental TNRB error involves treating the transferable amount as a fixed monetary sum rather than a percentage. Practitioners who record "GBP 200,000 unused NRB" instead of calculating "61.5384% unused" produce incorrect claims wherever the NRB at first death differs from the NRB at the survivor's death.13

Worked correction. Edward dies in 1999-2000 (NRB: GBP 231,000). His will leaves GBP 100,000 to children and the residue to his wife Frances (spouse exempt). VT = GBP 100,000; E = GBP 131,000; NRBMD = GBP 231,000. The transferable percentage is (131,000 / 231,000) x 100 = 56.7100% (rounded to four decimal places per IHTM43020).

Frances dies in 2026-27 (NRB: GBP 325,000). The enhanced NRB is GBP 325,000 + (GBP 325,000 x 56.7100%) = GBP 325,000 + GBP 184,307 = GBP 509,307.

A practitioner who recorded "GBP 131,000 unused" and added this to the current NRB would calculate an enhanced NRB of GBP 456,000 -- understating the available allowance by GBP 53,307, which at 40% equates to GBP 21,323 in overpaid IHT.13

Diagnostic checkpoint. Practitioners should verify that their file records the transferable percentage to four decimal places, not a monetary amount, particularly for first deaths occurring when the NRB was below GBP 325,000. This error is especially prevalent in cases where the first death occurred in the 1990s or early 2000s, when NRB values ranged from GBP 150,000 to GBP 263,000.

A related misconception involves assuming that where IHT was paid on the first death, no TNRB is available. IHTM43024 demonstrates otherwise: where a failed PET cumulates with an earlier CLT that is outside the seven-year window relative to the death estate, partial TNRB can remain available. The IHTM43024 worked example shows 20% of the NRB remaining transferable despite GBP 40,000 of IHT being payable on a failed PET.18

4. Error Category 2: Failure to Claim

TNRB must be claimed; it does not arise automatically on the survivor's death. Failure to file IHT402 or IHT217 within the permitted period can result in permanent loss of up to GBP 130,000 in IHT savings.141516

The IHT402 was updated for 2025-26, with changes to questions 12, 13, 18, and 19 reflecting the residence-based IHT regime, and removal of the pensions box.14 Practitioners using archived versions of the form risk submitting incorrect or incomplete claims. For excepted estates where the full NRB is available for transfer, IHT217 provides a simplified route; however, the conditions are specific: the first death must be on or after 13 November 1974 (for spouses) or 5 December 2005 (for civil partners), the first spouse must have been UK domiciled or a long-term UK resident, and the first estate must not have included settled property, gifts with reservation, or CLTs.15

Late claim provisions. IHTM43009 outlines the circumstances in which HMRC may exercise discretion to accept late claims: postal disruption causing loss or delay; records lost through fire, flood, or theft; serious illness of the claimant or a close relative; or where the claimant was unaware and could not reasonably have been aware of the entitlement.19 All late claims require referral to a manager for consistent treatment. Practitioners who assume that an expired time limit ends the matter may abandon valid claims where discretionary relief is available.

Provisional claims. Where documentation is difficult to obtain before time limits expire -- particularly for historical first deaths -- HMRC permits provisional claims under IHTM43006.20 Awareness of this facility is critical; practitioners who wait for complete documentation before filing risk missing the permitted period entirely.

5. Error Category 3: Lifetime Transfer Misapplication

The enhanced NRB resulting from a TNRB claim applies exclusively on the survivor's death. It does not increase the NRB available against chargeable lifetime transfers made by the survivor during their lifetime.21 However, where a CLT by the survivor becomes additionally chargeable on death within seven years, the enhanced NRB does reduce the additional tax arising. Conflating these two positions leads to either undercharging IHT on lifetime transfers or providing over-optimistic planning advice.

Worked illustration (per IHTM43034). Ruth's late husband Jim used only 20% of his NRB, leaving 80% transferable. Ruth gifts GBP 500,000 to a discretionary trust in July 2005 (NRB: GBP 275,000). Trustees pay lifetime IHT at 20% on the excess of GBP 225,000 (GBP 45,000). Ruth dies in February 2008. Her enhanced NRB is GBP 300,000 + (GBP 300,000 x 80%) = GBP 540,000. Because GBP 540,000 exceeds the GBP 500,000 CLT, no additional death tax is due on the trust gift. The original GBP 45,000 lifetime charge remains non-recoverable. The remaining enhanced NRB (GBP 40,000) applies against the death estate.21

The error in practice. Practitioners who advise surviving spouses that their TNRB-enhanced NRB reduces the lifetime tax charge at the point of making a CLT are providing incorrect advice. The enhancement operates only retrospectively on the death charge and the additional charge arising from death within seven years of a CLT. This distinction carries particular significance for clients considering large discretionary trust settlements: the 20% lifetime rate applies against the survivor's own NRB only, not the enhanced NRB. Advice that conflates the two positions may lead clients to make larger CLTs than intended, exposing them to tax charges that the TNRB cannot mitigate during their lifetime.

6. Error Category 4: Legacy NRB Discretionary Trust Misassessment

Pre-2007 wills commonly included NRB discretionary trust provisions, directing assets up to the NRB into trust on first death with the residue passing to the surviving spouse. HMRC acknowledges at IHTM43016 that many such trusts were never properly constituted, particularly where the sole asset was a half share of the matrimonial home held on a joint tenancy that was never severed.22

The determination is binary and carries maximum financial consequence:

  • Trust constituted: the NRB was used on first death; no TNRB (or reduced TNRB) is available; trust assets are subject to the relevant property regime with 10-yearly charges.
  • Trust not constituted: the full spouse exemption applied on first death; the full NRB remains unused and available for transfer via TNRB.22

RNRB interaction. Where a qualifying residential interest is held within a constituted NRB discretionary trust, the RNRB is unavailable unless a s.144 IHTA 1984 appointment to a direct descendant is made within two years of death.23 A legacy NRB discretionary trust holding the former matrimonial home can therefore defeat both TNRB and RNRB if not correctly managed -- a compounding loss that can exceed GBP 200,000 in tax terms.

Diagnostic checklist. Practitioners should: (1) obtain the first death's will and identify any NRB trust provisions; (2) establish whether the property was held as joint tenants or tenants in common; (3) determine whether the tenancy was severed before or after the first death; (4) verify whether trust assets were actually appropriated or transferred to the trustees; (5) confirm the position with HMRC on a case-by-case basis per IHTM43016.22 The practical challenge is that many solicitors who drafted these wills in the 1990s and early 2000s did not follow through with the post-death administrative steps required to constitute the trust, leaving the surviving spouse in a beneficial but often undocumented position.

7. Error Category 5: Multiple-Marriage Cap Oversight and Cascading Claims

The 100% Cap

Section 8A(5) limits the aggregate transferable percentage to 100% of the NRB at the survivor's death.17 Practitioners advising clients with multiple prior marriages must calculate cumulative percentages and recognise that excess percentages are wasted.

Worked illustration (per IHTM43030). Mei's first husband Cheng dies in 2002, leaving 60% of his NRB unused. Mei's second husband Jack dies in 2005, leaving 20% unused. Mei dies in 2008 (NRB: GBP 300,000). Enhanced NRB: GBP 300,000 + (GBP 300,000 x 60%) + (GBP 300,000 x 20%) = GBP 300,000 + GBP 180,000 + GBP 60,000 = GBP 540,000. The aggregate 80% is within the 100% cap.24

Had Cheng's unused percentage been 85% and Jack's 40%, the total would be 125% -- exceeding the cap. Only 100% would be available, equivalent to GBP 600,000 (double the then-NRB), and 25% would be wasted. Practitioners must perform the aggregation calculation before advising on the available enhancement.

The Cascading Claim Opportunity

A frequently overlooked dimension involves chains of marriages. IHTM43035 permits personal representatives on the last death to include a TNRB claim on an earlier death where no claim was made on the intermediary death, provided it does not affect tax payable on that intermediary death.25 The IHTM43035 worked example demonstrates that failing to identify a cascading claim can reduce the ultimate available NRB from GBP 650,000 to GBP 357,500 -- a difference of GBP 292,500 in tax-free allowance, equating to GBP 117,000 in IHT at 40%.25

Diagnostic checkpoint. For clients who have had multiple marriages, practitioners should map the full chain of prior deaths, establish the transferable percentage from each, and specifically investigate whether any intermediate spouse held unclaimed TNRB from a prior marriage. This requires obtaining documentation not just for the immediately predeceased spouse, but for all prior deaths in the chain.

8. Error Category 6: Residence-Based Regime Misapplication

From 6 April 2025, the residence-based IHT regime replaced domicile with long-term UK residence (LTUR) as the connecting factor for IHT purposes, enacted via Finance Act 2025, Part 2, Chapter 4.3 An individual is subject to UK IHT on worldwide assets if they have been UK tax resident for at least 10 of the 20 tax years preceding the chargeable event.26

This change directly affects the TNRB calculation. IHTM43042 now references long-term UK residence: where the first spouse was not a long-term UK resident (or, for pre-April 2025 deaths, was not UK domiciled), VT is calculated by reference to UK-situs assets only.27 Assets held outside the UK by a person not meeting the LTUR/domicile test are excluded from VT, which can produce a substantially higher transferable percentage than practitioners might anticipate.

Worked illustration (per IHTM43042). Abdul was domiciled abroad with only a US$250,000 bank account in the UK; his remaining estate was overseas and passed to his son Jamil. Because only the UK-situs account was potentially subject to UK IHT, VT was calculated by reference to that amount alone. Abdul's widow Soroya, who later became a long-term UK resident, could claim transfer of Abdul's substantially unused NRB.27

The errors. Practitioners who apply the old domicile-based rules to deaths on or after 6 April 2025 will misidentify the relevant connecting factor. Those who include worldwide assets in VT for a non-LTUR first spouse will understate the transferable percentage. Conversely, practitioners who fail to account for the restricted spouse exemption under IHTA 1984 s.18(2) -- which limits the exemption to GBP 325,000 where the surviving spouse is not a long-term UK resident -- may overestimate the available TNRB on the intermediary death.28

Transitional consideration. Where the first death occurred before 6 April 2025, the domicile-based rules determine VT; where it occurred on or after that date, the LTUR test applies. Practitioners handling estates that straddle the transition date must apply the correct regime to each death in the chain. This transitional complexity is compounded by the tail provisions: an individual who leaves the UK retains LTUR status for a further period based on prior residence duration, potentially up to 10 years, creating cases where the LTUR test produces different results from the former domicile test.26

9. Error Category 7: Historical Death Reconstruction Failures

Where the first death occurred decades ago -- particularly under Estate Duty (pre-13 March 1975) or Capital Transfer Tax (13 March 1975 to 17 March 1986) -- practitioners must reconstruct the historical tax position using period-specific thresholds and exemption rules.29

Critical historical variables:

  • Before 22 March 1972: no spouse or charitable exemption applied under Estate Duty
  • 22 March 1972 to 12 November 1974: spouse exemption limited to GBP 15,000
  • From 13 November 1974: unlimited spouse exemption for UK-domiciled spouses
  • Agricultural and business property relief under Estate Duty operated as relief against duty (not a capital reduction); where relief applied, duty must have been payable and the nil-rate equivalent was fully used29

The error. Practitioners who apply modern exemption rules to historical deaths -- assuming, for instance, that a pre-1972 estate passing entirely to the surviving spouse attracted full spouse exemption -- will miscalculate the transferable percentage. Similarly, failure to obtain historical documentation (grants of representation, wills, estate accounts) creates evidentiary gaps that can delay or jeopardise claims.

Remedy pathway. HMRC permits provisional claims where documentation is incomplete per IHTM43006.20 Practitioners who are unaware of this facility may abandon valid claims for historical first deaths where records are difficult to locate. Period-specific NRB equivalents (or nil-rate thresholds under Estate Duty and CTT) are tabulated at IHTM43060, providing an essential reference for historical calculations.29 Probate registries can supply copies of historical grants of representation, and the National Archives may hold relevant records for deaths dating back several decades.

10. Error Category 8: TNRB in Isolation -- Ignoring the Three-Allowance Landscape

From April 2026, practitioners must coordinate three transferable allowances: the NRB, the RNRB, and the new APR/BPR allowance. The APR/BPR allowance provides 100% relief capped at GBP 2.5 million per individual (raised from GBP 1 million by the 23 December 2025 announcement), with 50% relief above that threshold.4 Crucially, the allowance is transferable between spouses, and HMRC's Trusts and Estates Newsletter of February 2026 confirms transferability including where the first death occurred before 6 April 2026.30

The interaction between TNRB and RNRB taper deserves particular attention. The NRB (including any TNRB enhancement) is applied before the RNRB in the IHT calculation. Maximising the TNRB claim therefore reduces the estate value before the RNRB taper is assessed -- a sequence that becomes critical when pension death benefits enter the IHT estate from 6 April 2027.10 RNRB statistics for 2022-23 show 30,600 estates claimed the relief, sheltering GBP 7.72 billion of chargeable estate value.7 Once pension funds inflate estate totals, the GBP 2 million RNRB taper threshold will capture significantly more estates, making even small TNRB calculation errors consequential for RNRB entitlement.

The error. Practitioners who focus narrowly on TNRB without assessing its impact on RNRB taper exposure -- and who fail to plan for the coordination of three transferable allowances -- risk sub-optimal overall IHT outcomes. A holistic assessment requires modelling the TNRB claim's effect on: (a) the death estate value for RNRB taper purposes; (b) the available RNRB (and transferred RNRB); and (c) the APR/BPR allowance utilisation, particularly for estates containing qualifying agricultural or business property. The pension inclusion from April 2027 adds a fourth variable: pension death benefits that pass to the surviving spouse will attract the spousal exemption, but benefits passing to non-spouse beneficiaries will count toward the estate value and potentially trigger the RNRB taper.10

Conclusion: A Diagnostic Framework for Practice

The eight error categories identified in this article -- the fixed-amount fallacy, failure to claim, lifetime transfer misapplication, legacy NRB trust misassessment, multiple-marriage cap oversight, residence-based regime misapplication, historical death reconstruction failures, and failure to coordinate with the three-allowance landscape -- are not theoretical. Each arises regularly in practice and carries direct financial consequences for the estates that tax advisors administer.

With HMRC's compliance activity intensifying and three concurrent legislative changes creating new analytical requirements, practitioners may wish to adopt a systematic diagnostic approach to every TNRB claim. The following checklist summarises the essential verification points:

  1. Percentage, not amount: has the transferable percentage been calculated to four decimal places using E / NRBMD x 100?
  2. Claim filed: has IHT402 or IHT217 been submitted within the permitted period, using the current version of the form?
  3. Lifetime transfers distinguished: has the enhanced NRB been applied only to the death charge and any additional charge on CLTs within seven years, not to the original lifetime charge?
  4. Legacy trusts assessed: has any NRB discretionary trust in the first death's will been evaluated for constitution, with evidence obtained?
  5. Multiple marriages mapped: have all transferable percentages been aggregated and tested against the 100% cap, with cascading claims investigated?
  6. Residence-based regime applied: for first deaths on or after 6 April 2025, has VT been calculated using the LTUR test rather than domicile?
  7. Historical position reconstructed: for pre-1986 first deaths, have period-specific thresholds and exemption rules been applied?
  8. Three-allowance coordination: has the TNRB claim been modelled for its impact on RNRB taper and APR/BPR allowance utilisation?

The value of the TNRB continues to grow in real terms as the NRB freeze persists. Equally, the consequences of errors grow alongside it. A systematic, error-aware approach to every claim is the most reliable safeguard against both tax overpayment and HMRC compliance risk.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Inheritance Tax, Estate Administration, Tax Compliance, Probate Accounting

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Calculate the transferable nil-rate band percentage using the E / NRBMD x 100 formula to four decimal places and distinguish this from the fixed-amount fallacy
  2. Evaluate whether a legacy NRB discretionary trust was properly constituted and assess its binary impact on TNRB availability using the IHTM43016 diagnostic criteria
  3. Apply the residence-based IHT regime (from 6 April 2025) to TNRB VT calculations for estates involving non-long-term-UK-resident first spouses
  4. Analyse the interaction between TNRB claims, RNRB taper exposure, and the emerging three-allowance coordination requirement encompassing NRB, RNRB, and APR/BPR

Competency Mapping

  • ICAEW Code of Ethics: Professional Competence and Due Care (Section 113) -- maintaining current knowledge of IHT legislative developments
  • ATT Professional Rules and Practice Guidelines: Obligation to provide technically accurate tax advice based on current legislation
  • SRA Competence Statement: Section A3 -- maintaining and developing technical knowledge and skills

Reflective Questions

  1. How would the inclusion of pension death benefits from April 2027 alter the TNRB claim strategy for estates currently under administration that are close to the GBP 2 million RNRB taper threshold?
  2. What additional due diligence steps should be implemented when encountering a pre-2007 will containing NRB discretionary trust provisions, given the binary TNRB consequence of the constituted versus unconstituted determination?
  3. How effectively does the current case management system within the practice capture the transferable percentage (rather than a fixed monetary amount) for first deaths where files may have been opened years or decades ago?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-26. 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. HMRC Tax Receipts and National Insurance Contributions 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 ↩

  2. HMRC IHT Investigation Data obtained via Freedom of Information requests, as reported by MoneyWeek (February 2026). https://moneyweek.com/personal-finance/inheritance-tax/inheritance-tax-investigations-underpayment ↩ ↩2

  3. Finance Act 2025, Part 2, Chapter 4 -- Residence-Based IHT Regime. https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩ ↩2 ↩3

  4. 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

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

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

  7. HMRC Inheritance Tax Liabilities Statistics Commentary (2022-23). https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩ ↩2 ↩3

  8. OBR -- Inheritance Tax Forecasts. https://obr.uk/forecasts-in-depth/tax-by-tax-spend-by-spend/inheritance-tax/ ↩

  9. Taxes Management Act 1970, s.34 (ordinary time limit of 4 years) and s.36 (extended time limits: 6 years for careless behaviour, 20 years for deliberate behaviour). https://www.legislation.gov.uk/ukpga/1970/9/section/34; https://www.legislation.gov.uk/ukpga/1970/9/section/36 ↩

  10. GOV.UK -- Pensions and IHT from April 2027. 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 ↩3

  11. IHTA 1984, s.8A -- Transferable Nil-Rate Band. https://www.legislation.gov.uk/ukpga/1984/51/section/8A ↩

  12. Finance Act 2008. https://www.legislation.gov.uk/ukpga/2008/9 ↩

  13. IHTM43020 -- Calculation Methodology. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43020 ↩ ↩2 ↩3

  14. GOV.UK -- IHT402 Claim to Transfer Unused Nil-Rate Band. https://www.gov.uk/government/publications/inheritance-tax-claim-to-transfer-unused-nil-rate-band-iht402 ↩ ↩2 ↩3

  15. GOV.UK -- IHT217 for Excepted Estates. https://www.gov.uk/government/publications/inheritance-tax-claim-to-transfer-unused-nil-rate-band-for-excepted-estates-iht217 ↩ ↩2 ↩3

  16. IHTM43007 -- Time Limits for TNRB Claims. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43007 ↩ ↩2

  17. IHTA 1984, s.8A(5) -- 100% Cap. https://www.legislation.gov.uk/ukpga/1984/51/section/8A ↩ ↩2

  18. IHTM43024 -- TNRB Despite IHT Paid on First Death. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43024 ↩

  19. IHTM43009 -- Late Claims. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43009 ↩

  20. IHTM43006 -- How to Make a TNRB Claim. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43006 ↩ ↩2

  21. IHTM43034 -- CLTs by Surviving Spouse. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43034 ↩ ↩2

  22. IHTM43016 -- Unconstituted NRB Discretionary Trusts. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43016 ↩ ↩2 ↩3

  23. IHTM46013 -- RNRB: Property Held in Trust; IHTA 1984, s.144. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm46013 ↩

  24. IHTM43030 -- Multiple Spouses. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43030 ↩

  25. IHTM43035 -- Cascading Claims. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43035 ↩ ↩2

  26. Tax Adviser Magazine -- Long-Term Residence: The New Key Inheritance Tax Status. https://www.taxadvisermagazine.com/article/long-term-residence-new-key-inheritance-tax-status ↩ ↩2

  27. IHTM43042 -- Domicile/LTUR and TNRB. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43042 ↩ ↩2

  28. IHTM11033 -- Spouse Exemption (Non-UK Domiciled/LTUR). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm11033 ↩

  29. IHTM43060 -- Estate Duty and CTT. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm43060 ↩ ↩2 ↩3

  30. HMRC Trusts and Estates Newsletter (February 2026). https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-february-2026 ↩

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