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The impact of pre-2006 IHT planning on transferable nil rate bands

Shared from Tax Insider: The impact of pre-2006 IHT planning on transferable nil rate bands
By Latha Rodgers, February 2025

Latha Rodgers points out that ‘old’ inheritance tax planning may need to be revisited in some cases. 

A common assumption is that inheritance tax (IHT) is only payable on the second death if a married couple or civil partner’s total net estate is more than £1m.  

However, this may not be the case if pre-2006 IHT planning was undertaken.  

The main IHT bands  

The two IHT bands available on death are the nil-rate band (NRB) and the residence nil-rate band (RNRB). Both the NRB and RNRB are frozen at £325,000 and £175,000 respectively until April 2030.  

The NRB is available regardless of the individual’s domicile position and the total value of their gross estate.  

However, the RNRB is only available if a direct descendant inherits the residence, and the band is tapered if

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