Budget 2026: Inheritance Tax
Nil rate bands, and Inheritance Tax rates
No major changes have been announced in relation to IHT, meaning that the Nil Rate Band (NRB) and Residential Nil Rate Band continue to remain frozen, despite inflation levels, at their current rates of £325,000 and £175,000 respectively. IHT rates also remain unchanged.
Gravita’s view
It has been a very long time since the NRB was increased, and no one really expected it to rise given last year’s announcement that it would remain frozen until April 2031.
BPR and APR
No further announcements have been made regarding either Business Property Relief (BPR) or Agricultural Property Relief (APR). As a result, the newly introduced £2.5 million combined threshold for 100% relief will remain in place, with 50% relief applying to any excess. As announced last year, these allowances will be transferable between spouses and civil partners.
Gravita’s view
Again, no one expected this to change. Hoped, perhaps, but not expected. It appears that the Chancellor’s reference to “protecting the passing on of family businesses” related instead to the changes to CGT reliefs surrounding intangibles, which are covered in more detail in our CGT section.
Minor technical amendments to extension of Inheritance Tax (IHT) to pensions from April 2027
From April 2027, undrawn pensions will be brought into charge for IHT purposes, which we already knew. Further legislation will now be included allowing a prospective personal representative to direct pension scheme administrators to pay the inheritance tax due to HMRC when certain conditions are met. Those administering an estate will be allowed to decide whether notional pension property is included in the ‘general’ component of the estate or as a separate component for the purposes of calculating the reduced rate of inheritance tax when part of the estate is left to charity.
Gravita’s view
No one is looking forward to this change, which undoes a lot of historic financial and tax planning and it likely to be administratively onerous. The concession allowing pension assets to be separated from the general component is helpful because it means individuals who have structured their wills to leave sufficient assets to charity in order to benefit from the reduced IHT rate will not need to increase charitable gifts significantly beyond their original intentions.
Admittedly, sectioning off the Pension will still mean that the Pension element may not qualify for the reduced rate and will still suffer 40% IHT (plus potentially income tax).
Preventing unintended deductions for liabilities in Trust arrangements
Inheritance Tax is charged on the net value of property transferred on death and on certain lifetime transfers. Liabilities may be deducted in calculating taxable value but includes anti-avoidance provisions that stop liabilities arising under avoidance arrangements from inappropriately reducing Inheritance Tax charges. In certain circumstances involving settled property, liabilities may reduce Inheritance Tax charges in a way that is inconsistent with the intended operation of the legislation.
With immediate effect, legislation will provide a statutory rule for taking liabilities properly incurred by trustees into account when valuing settled property for inheritance tax purposes. It will also align their treatment with personal liabilities and extend existing debt deduction restrictions and anti-avoidance rules to ensure that certain liabilities funded using value originating from a beneficiary’s own estate cannot reduce inheritance tax charges.
Gravita’s view
HMRC has clearly identified some sort of scheme that has been used to help trusts avoid IHT and is now seeking to close it down.
National Savings and Investment tracing issue
Announced ahead of the Budget, legislation will be introduced to prevent estates affected by the National Savings & Investments (NS&I) tracing error in respect of bereavement claims from facing disproportionate administrative burdens. The changes will also provide a full IHT exemption and an income tax easement on affected amounts. These measures will be retrospective where necessary, provided they do not increase anyone’s tax liability.
Reforming the Cultural Gift Scheme
Previously announced, from April 2027 jointly owned property will be allowed to be donated under the Cultural Gift Scheme, with relief calculated by reference to each donor’s beneficial entitlement to that property. The measure will also allow donors one opportunity, within the five-year limit period, to amend their remaining tax credit allocation.
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Budget 2026: Personal tax
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Budget 2026: Capital Gains Tax (CGT)
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