This well-established commentary gives private client advisers and accountants an expertly written and highly practical guide to the main planning points, potential pitfalls and possible solutions to consider when dealing with IHT and estate planning solutions.
The October 2024 Budget statement introduced some of the most consequential changes to the inheritance tax regime and the new edition of Ray and McLaughlin's Practical Inheritance Tax Planning is updated to take account of this new landscape.
The concept of domicile was removed from the UK tax system with effect from 6 April 2025. As such the scope of UK IHT on non-UK situated assets is no longer determined by an individuals domicile status; it is now judged on how long the individual has been resident in the UK. All individuals are affected whether they were domiciled in the UK or non-domiciled under the old rules. The changes to the residence based system also has an impact on the IHT treatment of trusts and excluded property (non-settled property situated outside the UK).
A further significant change covered in the updated edition is the change to to the IHT rules relating to Agricultural Property Relief and Business Property Relief (with exception of unlisted shares) with effect from 6 April 2026.
The commentary also reflects the change which means that inherited unused pensions and death benefits will be within a deceaseds estate for IHT purposes. There are important planning implications relating to all the these changes and the revised commentary will highlight these along with any identified pitfalls.
Key points will be highlighted throughout and all examples updated, with new ones being added where necessary.
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A long-established first port of call for private client advisers working with clients on inheritance tax planning engagements
Introduction and Outline
Residence and Domicile
Excluded Property
The Art of Giving
Gifts with reservation of benefit
Husband, wife and civil partner
Nil rate band
Residence nil rate band
The use of exemptions
Appropriate will planning
Practical aspects of will planning
Interest in possession settlements
Other varieties of settlement
Practical aspects of drafting settlements
Business interests
Business property relief
Agricultural property
Estate planning - woodland, heritage property and Lloyd's underwriters
Pensions, life assurance etc
Pre-owned assets
Compliance issues
John Bunker LL.B, CTA, TEP Solicitor is a freelance lecturer who is also Consultant Solicitor and Chartered Tax Advisor, Tax Trusts and Estates, for Irwin Mitchell LLP looking after technical and training work in this practice. He established this role following more than 25 years' specialist experience specializing in wills, trusts, estate and tax planning
Mark McLaughlin is a fellow of the CIOT and ATT, and a member of STEP. He contributes to a range of Bloomsbury Professional tax titles in both print and online formats.
Siobhan Duncan is a barrister at Temple Tax Chambers.
