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Trusts for High-Net-Worth Clients: When to Recommend, When to Refer

· 19 min

Executive Summary

The post-April 2025 inheritance tax landscape has materially lowered the wealth threshold at which trust planning becomes a necessary conversation for wealth managers. Frozen nil-rate bands through 2030-31, the enacted residence-based IHT regime under Finance Act 2025, the forthcoming inclusion of pension death benefits within IHT from April 2027, and reformed agricultural and business property reliefs from April 2026 collectively expand the cohort of estates requiring structured planning. Wealth managers occupy a pivotal but constrained position: they must identify when trust structures serve client objectives and initiate the planning conversation, while recognising the FCA regulatory perimeter that distinguishes regulated investment advice from legal structuring. This article provides a decision framework for determining when to recommend trust-wrapped solutions within advisory competence and when to refer to STEP-qualified trust and estate practitioners.

1. The Expanding Trust Planning Cohort

The IHT nil-rate band has remained at GBP 325,000 since April 2009, and the residence nil-rate band at GBP 175,000 since April 2020. Both are now frozen through at least 2030-31, with no indexation planned.1 This prolonged freeze, set against sustained asset price inflation, continues to draw estates that would historically have fallen below the planning threshold into IHT liability territory. While more than 90% of estates are forecast to have no IHT liability in each of the next five years, the taxable cohort is expanding, and the concentration of liability among high-net-worth estates is intensifying.2

The maximum combined transferable allowance for a surviving spouse or civil partner stands at GBP 1 million -- comprising GBP 650,000 in transferred NRB and GBP 350,000 in transferred RNRB.1 For high-net-worth clients, these allowances represent a diminishing fraction of total estate value. The RNRB itself tapers at GBP 1 for every GBP 2 above the GBP 2 million threshold, and is entirely lost at GBP 2.35 million for an individual estate (GBP 2.7 million where the inherited RNRB applies).1 Estates above this taper ceiling derive no benefit from the RNRB, reinforcing the case for alternative IHT mitigation strategies including trust-based planning.

The interaction between the frozen thresholds and residential property values is particularly acute. In regions where average property values have risen above GBP 500,000, the NRB represents less than two-thirds of the property value alone -- before other estate assets are considered. For wealth management clients with diversified portfolios, investment property, and pension accumulations, the gap between estate value and available reliefs continues to widen annually in the absence of threshold indexation.

Pension Death Benefits: A New Planning Catalyst

From 6 April 2027, unused pension funds and death benefits will be included within the deceased's estate for IHT purposes.3 This represents a fundamental shift: most UK registered pension schemes are structured as discretionary trusts, and until now the exercise of trustee discretion over death benefit payments has kept these assets outside the IHT estate. The government estimates that 10,500 estates will become newly liable for IHT as a result, with a further 38,500 estates paying increased IHT. The average additional IHT liability is projected at approximately GBP 34,000.3

Critically, personal representatives -- not pension scheme administrators -- will bear responsibility for reporting and paying IHT on pension death benefits.4 Draft legislation published in July 2025 confirmed the mechanism by which personal representatives may direct scheme administrators to withhold benefits to satisfy IHT liabilities.4 This creates a new advisory touchpoint: wealth managers who have historically treated pension drawdown strategies and estate planning as separate conversations must now integrate them. The April 2027 change is a catalyst not only for new trust planning but for reviewing existing arrangements where pension wealth forms a material proportion of the estate.

A double taxation risk exists where pension death benefits attract both income tax (on the recipient) and IHT (on the estate), though draft legislation includes provisions to remove income tax from the portion paid as IHT.4 Spousal and civil partner exemptions are maintained, as are charity exemptions, and death-in-service benefits from defined benefit arrangements remain excluded.3 Nevertheless, the net effect is a material expansion of the estates for which structured IHT mitigation -- including trust planning -- warrants active consideration.

2. Trust Structures: A Practitioner Taxonomy

Selecting the appropriate trust structure requires balancing IHT efficiency against access to capital, ongoing tax costs, and compliance obligations. The following taxonomy addresses the structures most commonly encountered in wealth management practice, with particular attention to the trade-offs that inform the recommend-or-refer decision.

Discretionary Trusts

Discretionary trusts offer maximum flexibility: trustees hold assets on behalf of a class of beneficiaries, with no individual having a fixed entitlement. From an IHT perspective, discretionary trusts fall within the relevant property regime under the Inheritance Tax Act 1984.5 This regime imposes three categories of charge: an entry charge of 20% on chargeable lifetime transfers exceeding the available NRB (or 25% where the settlor pays the tax); a ten-year periodic charge of up to 6% of trust value above the available NRB, calculated as 30% of the effective lifetime rate; and proportionate exit charges when property ceases to be relevant property between periodic charge dates.67

From 26 November 2025, new rules apply when relevant property becomes excluded property under section 48ZA of IHTA 1984, reflecting the transition to the residence-based regime.5 Many discretionary trusts remain below the threshold at which charges arise in practice, and even where charges apply, the effective rate is typically significantly below the 40% IHT rate on death. This differential is a core part of the planning rationale, but it must be weighed against the ongoing administrative burden and the RNRB sacrifice.

A critical planning consideration that practitioners frequently underweight is the RNRB interaction. Property held in a discretionary trust on death does not qualify for the RNRB, even where the beneficiaries are direct descendants of the deceased.18 For a client whose estate would otherwise benefit from the full RNRB allowance, settling property into a discretionary trust sacrifices up to GBP 175,000 of additional nil-rate band (GBP 350,000 for a married couple or civil partners). This trade-off must be quantified in any suitability assessment: for some estates, the RNRB sacrifice may exceed the IHT saving generated by the trust structure itself.

To illustrate: consider a married client with a GBP 2.5 million estate (excluding the family home) and a spouse whose estate is valued at GBP 500,000. At GBP 2.5 million, the RNRB is fully tapered to nil for the first spouse's estate. If GBP 500,000 is settled into a discretionary trust, the periodic charge cost over a 10-year cycle (assuming 4% annual growth) is modest -- approximately GBP 3,600 at the first 10-year anniversary -- but the RNRB sacrifice on the second death, where the combined estate would otherwise attract the full transferred RNRB of GBP 350,000, represents a lost IHT saving of GBP 140,000 (40% of GBP 350,000). The planning rationale depends entirely on whether the expected growth rate within the trust, compounded over the planning horizon, generates IHT savings exceeding this cost. For estates materially above the GBP 2 million taper threshold, where the RNRB is already lost, this trade-off disappears and the discretionary trust becomes more clearly advantageous.

Loan Trusts

Loan trusts enable the settlor to retain access to capital through a repayable loan, while investment growth accrues within the trust and falls outside the estate for IHT purposes. The outstanding loan remains within the settlor's estate, but any growth above the loan value is immediately outside the IHT net.9 For clients who require ongoing capital access -- a common requirement among wealth management clients who are planning for later life as well as for succession -- loan trusts offer a pragmatic compromise between IHT mitigation and liquidity. The growth outside the estate is not a potentially exempt transfer and carries no seven-year survival requirement, making loan trusts particularly suitable for older clients or those with uncertain health prognoses.9 As the settlor repays segments of the loan and the trust invests and grows, the proportion of the trust fund outside the estate increases over time. Advisors should note that the loan must be genuinely repayable on demand; any arrangement that restricts repayment or converts the loan to a gift risks reclassification by HMRC, with consequent IHT implications.9

Gift Trusts and Discounted Gift Trusts

Gift trusts involve an outright transfer into trust, engaging the seven-year rule for potentially exempt transfers under section 3A of IHTA 1984 (where the trust is absolute) or creating an immediately chargeable lifetime transfer (where the trust is discretionary).10 The entire gifted amount is immediately outside the estate after seven years' survival, making gift trusts the most IHT-efficient structure for clients with surplus capital and no ongoing access requirement.

Discounted gift trusts enable the settlor to retain a right to regular withdrawals, with the "discount" -- representing the actuarial value of the retained rights -- falling outside the estate from inception. The discount is determined by reference to the settlor's age, health, and the level of retained income, and HMRC acceptance of the discount value is not guaranteed in every case.10 Both structures require careful suitability assessment: the settlor relinquishes capital irrevocably (in the case of gift trusts) or retains only limited, predetermined access (in the case of discounted gift trusts).

Bare Trusts

Bare trusts offer simplicity and transparent taxation: the beneficiary is absolutely entitled to the trust property, and income and gains are taxed as the beneficiary's own. The capital gains tax annual exempt amount for trusts is GBP 1,500, compared with GBP 3,000 for individuals, with gains above this amount taxed at 24%.11 For bare trusts, however, the beneficiary's own allowances apply, making them more tax-efficient than discretionary structures for income and capital gains purposes. Bare trusts are most commonly used for minors where the intention is outright transfer at majority, though the parental settlement rules apply where the settlor is a parent and the child is under 18.

3. The Residence-Based Inheritance Tax Regime and Trust Implications

The Finance Act 2025 enacted one of the most significant structural changes to UK IHT in a generation: the replacement of domicile with long-term UK residence as the connecting factor for IHT on foreign assets and trust property.1213 Under the new regime, an individual is a long-term UK resident if they have been UK-resident for at least 10 out of the last 20 tax years preceding the chargeable event.12 This change has profound implications for trust planning, particularly for internationally mobile HNW clients and those with connections to multiple jurisdictions.

Tail Provisions

The regime incorporates graduated tail provisions for individuals who cease UK residence. Those resident for 10 to 13 years remain in IHT scope for a minimum of 3 tax years after departure, rising to 10 years for longer-term residents.12 For wealth managers advising internationally mobile HNW clients, these tail provisions introduce a planning horizon that extends well beyond the year of departure. Trust structures established during the tail period remain subject to UK IHT charges, and advisors must ensure clients understand that emigration does not provide immediate IHT relief. The graduated nature of the tail provisions means that planning advice must be calibrated to the individual client's residence history, not applied as a generic rule.

Transitional Protections and the GBP 5 Million Cap

Property that constituted excluded property in a settlement immediately before 30 October 2024 may now be brought within the relevant property regime from 6 April 2025.14 However, a transitional cap of GBP 5 million per 10-year cycle applies to the IHT charges on such transitional trust property.15 This cap is a material planning consideration for former non-domiciled settlors: it limits the maximum periodic charge exposure while the underlying property remains within the trust. For trusts holding property valued significantly above GBP 5 million, the cap provides a degree of certainty that the previous excluded property status did not require.

Anti-avoidance provisions prevent trustees from manipulating asset situs before or after exit charges,16 and qualifying interest in possession settlements now depend on the long-term resident status of both the settlor and the person with the qualifying interest.17 The complexity of these provisions underscores the need for specialist involvement in trust planning for internationally connected clients. Wealth managers should not attempt to advise on the interaction between residence status, excluded property rules, and trust charges without engaging appropriately qualified legal and tax practitioners.

Practical Advisory Implications

The residence-based regime demands that wealth managers incorporate a residency analysis into their standard client review process. Even where the advisor does not establish the trust structure, understanding whether a client is or may become a long-term resident -- and the consequent IHT implications for foreign-situs assets -- is essential for identifying the trust planning opportunity and triggering the appropriate referral. For clients approaching the 10-year residence threshold, the planning window is time-sensitive, and early identification by the wealth manager enables timely specialist engagement.

4. The Regulatory Perimeter: Recommend Versus Refer

The FCA regulatory perimeter defines the boundary between activities that wealth managers may lawfully perform and those that require referral to appropriately qualified legal practitioners. Understanding this boundary is not an academic exercise: suitability failures on trust-related recommendations carry regulatory consequences, and providing trust structuring advice outside the perimeter exposes the firm to both regulatory sanction and professional liability.

Within the FCA Perimeter: Trust-Wrapped Investments

Recommending trust-wrapped investment solutions -- including loan trusts, gift trusts, and discounted gift trusts offered by product providers -- falls within FCA-regulated advice where the underlying investment is a designated investment. The suitability obligations under COBS 9A.2 apply: firms must ensure that personal recommendations are suitable, having assessed the client's knowledge and experience, financial situation, and investment objectives.18 Suitability reports are required for retail client personal recommendations under COBS 9.4.19

FCA data indicates that ongoing suitability reviews are delivered in approximately 83% of cases, with 15% of clients declining or not responding to the review process.20 For trust-wrapped investments, the ongoing review obligation is particularly significant: the trust structure introduces additional complexity that must be factored into the suitability assessment at each review cycle, including the ten-year periodic charge horizon for discretionary trust structures. The approaching pension IHT changes from April 2027 add a further dimension: suitability reviews conducted between now and April 2027 should consider whether existing trust-wrapped arrangements remain optimal once pension death benefits enter the IHT estate.

Establishing the trust deed, selecting the trust type for non-investment purposes, drafting trust terms, and advising on the legal implications of trust structures constitute legal services that fall outside the FCA perimeter. These activities require solicitor involvement and, for complex arrangements, engagement with STEP-qualified trust and estate practitioners (TEPs).21

The practical boundary operates as follows: a wealth manager may identify that a client's circumstances warrant trust-based IHT planning, recommend a specific trust-wrapped investment product having assessed suitability, and facilitate the investment into that product. However, the wealth manager should not draft trust documentation, advise on the selection of trustees, or recommend trust structures that are not investment-product-based without involving a qualified legal practitioner. The FCA's 2025-30 Strategy, with its emphasis on deepening trust in financial services and rebalancing risk, reinforces the importance of operating within competence boundaries.22

Documenting the Recommendation-Referral Decision

The suitability file should record the rationale for each trust-related recommendation or referral. Where a recommendation is made within competence, the file should evidence the suitability assessment including the IHT position, the client's access-to-capital requirements, the ongoing charge implications, and the RNRB sacrifice where applicable. Where a referral is made, the file should record the basis for the referral -- typically that the client's needs extend beyond the FCA-regulated perimeter -- and the information provided to the receiving specialist. Maintaining this documentation protects the firm in the event of a subsequent complaint or regulatory inquiry and demonstrates adherence to the conduct standards expected of FCA-authorised firms.

5. Building the Multi-Disciplinary Referral Framework

Effective trust planning for HNW clients is inherently multi-disciplinary. The wealth manager identifies the planning opportunity; the solicitor or TEP establishes the legal structure; the accountant manages the ongoing tax reporting. Each professional operates within their regulatory framework, but the client experiences a single planning process. The quality of the referral framework determines whether that experience is coordinated or fragmented.

Identifying Specialist Practitioners

STEP membership and TEP designation provide the primary quality assurance signal for trust specialists. STEP's UK Technical Committee actively engages with HMRC on trust-related policy, including submissions on the treatment of non-UK domiciled taxpayers and their trusts under the new residence-based regime.21 STEP's Professional Standards Guidance Note on Reserved Legal Activities, published October 2025, provides a framework for understanding the boundary between trust advisory work and reserved legal activities.21

When selecting referral partners, wealth management firms should assess TEP qualification, specialist experience (particularly in the relevant trust types and client demographics), professional indemnity coverage, and willingness to participate in coordinated client planning. Establishing formal referral arrangements -- including agreed service levels, communication protocols, and fee transparency -- strengthens the client proposition and reduces the risk of advice gaps.

Structuring the Referral

The referral itself should communicate sufficient information for the receiving practitioner to assess the case without duplicating the fact-finding process. At minimum, this includes: the client's IHT position and projections; the specific trust planning objectives identified; the client's access-to-capital requirements; the pension position (particularly in light of April 2027 changes); any international element including long-term residency status; and existing trust arrangements.

The receiving practitioner should be expected to confirm the scope of their engagement, provide a fee estimate, and communicate the ongoing compliance obligations that the trust structure will create, including Trust Registration Service requirements. A feedback loop -- where the specialist confirms the trust structure established and the wealth manager updates the client's financial plan accordingly -- closes the advisory circle and ensures ongoing coordination.

APR/BPR Considerations for Business-Owner Clients

The reformed agricultural property relief and business property relief regime from April 2026 introduces the GBP 2.5 million 100% relief allowance, with 50% relief thereafter.2324 Anti-fragmentation rules apply to multiple trusts created by the same settlor on or after 30 October 2024, meaning the GBP 2.5 million allowance is shared across the settlor's trusts rather than available independently to each.25 For business-owner clients with qualifying assets above this threshold, coordinated trust and investment planning is essential, and the multi-disciplinary referral framework must accommodate accountants with specialist agricultural or business property expertise. Interest-free instalments over 10 years are available for qualifying APR/BPR property from April 2026, providing cash flow relief but not eliminating the underlying liability.23

Trust Registration Service: Ongoing Compliance

All UK express trusts must register on the Trust Registration Service within 90 days of creation, with changes reported within 90 days.26 As of the date of writing, draft regulations expanding the TRS scope to include non-UK trusts with UK land acquired before 6 October 2020 have completed consultation (September 2025), and the statutory instrument is expected to be laid before Parliament imminently; practitioners should monitor legislation.gov.uk for the SI publication.26 A de minimis exemption applies for trusts with assets not exceeding GBP 10,000, income not exceeding GBP 5,000 per annum, and non-financial assets not exceeding GBP 2,000.27 Penalties for non-compliance start at GBP 100 per failure.

The CRS/FATCA registration deadline for trusts classified as reporting financial institutions passed on 31 December 2025.28 Advisors must communicate to clients that trust establishment is not a one-off event: it creates ongoing compliance obligations that require monitoring and, in many cases, professional support. The compliance burden should be factored into the initial suitability assessment, particularly for clients who may not have the appetite or resources for ongoing trust administration.

Conclusion

The recommend-or-refer decision in trust planning is no longer a peripheral skill for wealth managers -- it is a core professional competency. The convergence of frozen nil-rate bands, the residence-based IHT regime, pension death benefit inclusion from April 2027, and reformed APR/BPR reliefs has lowered the effective wealth threshold at which trust planning warrants active consideration. The FCA regulatory perimeter provides a clear, if nuanced, boundary: trust-wrapped investment products fall within advisory competence; trust establishment and legal structuring require specialist referral.

Practitioners who develop structured referral frameworks, integrate residency analysis into standard client reviews, and anticipate the April 2027 pension changes in current planning conversations will be better positioned to serve the expanding cohort of clients for whom trust-based IHT mitigation is now a material consideration. The multi-disciplinary model -- wealth manager, solicitor or TEP, accountant -- is not an aspiration but a practical necessity for delivering comprehensive estate planning in the current regulatory and fiscal environment. Looking ahead, the ten-year periodic charge cycle for trusts established in the current planning window will first arise in the mid-2030s, and the ongoing TRS compliance obligations will require sustained professional engagement throughout.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Estate Planning, Trust Law, IHT Mitigation, Wealth Management Regulation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Distinguish between trust structures that fall within the FCA regulatory perimeter and those requiring specialist legal referral under COBS 9A.2 and PERG 8
  2. Evaluate the IHT implications of discretionary trusts, loan trusts, gift trusts, and discounted gift trusts, including the RNRB sacrifice for discretionary arrangements
  3. Analyse the impact of the residence-based IHT regime on trust planning for internationally mobile high-net-worth clients, including tail provision durations and the GBP 5 million transitional cap
  4. Apply the APR/BPR anti-fragmentation rules to determine how the GBP 2.5 million allowance is allocated across multiple trusts established by the same settlor

Competency Mapping

  • FCA COBS 9A.2 suitability assessment obligations for trust-wrapped investment recommendations
  • STEP Professional Standards Guidance on Reserved Legal Activities (October 2025)
  • HMRC IHT Manual: relevant property regime (IHTM04096, IHTM42081, IHTM42110)

Reflective Questions

  1. How does your current client review process identify whether a client's residency status triggers long-term resident treatment under the Finance Act 2025 regime, and what changes would you implement to integrate this analysis?
  2. When recommending trust-wrapped investment products, what steps do you take to quantify the RNRB sacrifice and communicate this trade-off to the client within the suitability report?
  3. How would you structure a referral to a STEP-qualified specialist to ensure continuity of advice and avoid duplication of the fact-finding process?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. HMRC, IHT nil-rate band and RNRB thresholds from 6 April 2026 (October 2025). 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 ↩ ↩2 ↩3 ↩4

  2. HM Treasury, Budget 2025 Overview of Tax Legislation and Rates (OOTLAR) (October 2025). https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar ↩

  3. HMRC, Inheritance tax on unused pension funds and death benefits (October 2024, updated July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3

  4. HMRC, Inheritance tax on pensions: liability, reporting and payment -- summary of responses (July 2025). https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩ ↩2 ↩3

  5. HMRC IHT Manual IHTM04096 -- Charges on relevant property trusts (updated November 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04096 ↩ ↩2

  6. HMRC IHT Manual IHTM42081 -- Ten-year anniversary introduction (updated November 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm42081 ↩

  7. HMRC IHT Manual IHTM42110 -- Proportionate charges introduction (updated November 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm42110 ↩

  8. HMRC, Inheritance Tax Residence Nil Rate Band Guidance. https://www.gov.uk/guidance/inheritance-tax-residence-nil-rate-band ↩

  9. HMRC IHT Manual IHTM20431 -- Loan trusts: IHT treatment of outstanding loans and trust growth (updated November 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm20431 ↩ ↩2 ↩3

  10. IHTA 1984 s.3A -- Potentially exempt transfers (as amended). https://www.legislation.gov.uk/ukpga/1984/51/section/3A ↩ ↩2

  11. HMRC, Trusts and Taxes: Types of Trust. https://www.gov.uk/trusts-taxes/types-of-trust ↩

  12. HMRC IHT Manual IHTM47020 -- Long-term UK residence test (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩ ↩2 ↩3

  13. Finance Act 2025, Schedule 13. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩

  14. HMRC IHT Manual IHTM47022 -- Transitional provisions (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47022 ↩

  15. HMRC, Capping IHT trust charges for former non-UK domicile residents (March 2025). https://www.gov.uk/government/publications/capping-inheritance-tax-trust-charges-for-former-non-uk-domicile-residents/cap-inheritance-tax-trust-charges-to-5m-for-former-non-uk-domiciles-from-6-april-2025 ↩

  16. HMRC, IHT anti-avoidance for non-long-term UK residents and trusts. https://www.gov.uk/government/publications/inheritance-tax-anti-avoidance-measures-for-non-long-term-uk-residents-and-trusts/inheritance-tax-anti-avoidance ↩

  17. HMRC IHT Manual IHTM47051 -- QIIPs (April 2025). https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47051 ↩

  18. FCA Handbook COBS 9A.2 -- Assessing suitability obligations. https://handbook.fca.org.uk/handbook/COBS/9A/2.html ↩

  19. FCA Handbook COBS 9.4 -- Suitability reports. https://handbook.fca.org.uk/handbook/COBS/9/4.html ↩

  20. FCA, Ongoing suitability reviews press release (2025). https://www.fca.org.uk/news/press-releases/fca-finds-vast-majority-ongoing-suitability-reviews-delivered ↩

  21. STEP Technical Guidance and Briefing Notes. https://www.step.org/policy/technical-guidance-and-briefing-notes ↩ ↩2 ↩3

  22. FCA Strategy 2025-2030. https://www.fca.org.uk/publication/corporate/our-strategy-2025-30.pdf ↩

  23. HMRC, Agricultural property relief and business property relief changes (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2

  24. HMRC, Summary of reforms to agricultural property relief and business property relief (December 2025). https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩

  25. HMRC, Reforms to IHT APR and BPR: application in relation to trusts -- summary of responses (December 2025). https://www.gov.uk/government/consultations/reforms-to-inheritance-tax-reliefs-consultation-on-property-settled-into-trust/outcome/reforms-to-inheritance-tax-agricultural-property-relief-and-business-property-relief-application-in-relation-to-trusts-summary-of-responses ↩

  26. HMRC Trust Registration Service Manual TRSM10030. https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm10030 ↩ ↩2

  27. STEP, Small non-taxpaying trusts to be exempted from TRS (2025). https://www.step.org/industry-news/small-non-taxpaying-trusts-be-exempted-compulsory-uk-trs-registration ↩

  28. ICAEW, Trusts must meet new registration requirement by 31 December (December 2025). https://www.icaew.com/insights/tax-news/2025/dec-2025/trusts-must-meet-new-registration-requirement-by-31-december ↩

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