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Free Form IHT421 Probate Summary Template

Form IHT421 is the United Kingdom HMRC probate summary that bridges Form IHT400 (the full Inheritance Tax account) and the Probate Registry. Once HMRC processes the IHT400 and issues clearance, the IHT421 is sent to the Probate Registry; the Probate Registry then issues the Grant of Probate (testate) or Letters of Administration (intestate). The IHT421 carries the gross estate value, the net estate value, the Net Qualifying Value (which drives the Probate Registry fee), and a signed personal representative declaration. Our free UK template builds a structured IHT421 — deceased identification, IHT reference, personal representative details, estate values and instalment option, with four Expert clauses on the Transferable Nil Rate Band, RNRB taper, gift with reservation of benefit and the seven-year PET tapering schedule under the Inheritance Tax Act 1984.

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Form IHT421 — Probate Summary
HMRC -> Probate Registry Handover  ·  IHT Reference IHT-2026-MW-440829  ·  8 June 2026
TO: District Probate Registry at Leeds

RE: Application for Grant of Probate in the estate of Margaret Anne Whitmore, deceased.

Form IHT421 is the HMRC handover document confirming that the personal representatives have filed Form IHT400 (Inheritance Tax Account) on 22 May 2026 under HMRC IHT reference IHT-2026-MW-440829, and (where applicable) have paid the Inheritance Tax due on the first instalment.

The Probate Registry is asked to issue Grant of Probate on receipt of this IHT421 alongside the corresponding PA1P / PA1A application (reference PA1P-2026-04-1188-WMR).
1. DECEASED PARTICULARS
FULL NAMEMargaret Anne Whitmore
DATE OF BIRTH4 July 1942
DATE OF DEATH18 February 2026
LAST PERMANENT ADDRESS24 Beechwood Drive, Harrogate, North Yorkshire HG2 8QL
DOMICILE AT DEATHEngland and Wales (the deceased was domiciled in England and Wales at the date of death)
2. HMRC INHERITANCE TAX REFERENCE
IHT REFERENCE NUMBERIHT-2026-MW-440829
FORM IHT400 FILED22 May 2026
ACCOUNT SIGNED8 June 2026
3. PERSONAL REPRESENTATIVE
FULL NAMEChristopher James Whitmore
ADDRESS11 Park View Court, Harrogate, North Yorkshire HG1 4SR
TELEPHONE07810 552043
EMAILcj.whitmore@example.co.uk
CAPACITYexecutor named in the deceased's will, granted probate under section 116 of the Senior Courts Act 1981
GRANT SOUGHTGrant of Probate
PA1P / PA1A REFERENCEPA1P-2026-04-1188-WMR
NUMBER OF PERSONAL REPRESENTATIVES APPLYING FOR THE GRANT2
4. ESTATE VALUE SUMMARY
GROSS VALUE OF THE ESTATEGBP 1,850,000
NET VALUE OF THE ESTATEGBP 1,685,000
INHERITANCE TAX DUE (TOTAL)GBP 128,000
INHERITANCE TAX PAID BEFORE GRANTGBP 128,000
PAYMENT ROUTEpaid in full to HMRC by direct bank transfer or CHAPS from the deceased's estate funds (or via the IHT Direct Payment Scheme where the bank releases funds directly to HMRC)
5. NET QUALIFYING VALUE (NQV) FOR GRANT PURPOSES
NET QUALIFYING VALUE (NQV)GBP 1,685,000
SPOUSE / CIVIL PARTNER EXEMPT SHARE (IHTA 1984 S.18)GBP 0
CHARITY EXEMPT SHARE (IHTA 1984 S.23)GBP 50,000
PROBATE REGISTRY DESTINATIONDistrict Probate Registry at Leeds
STATEMENT OF TRUTHConfirmed - PR signs below
6. TRANSFERABLE NIL RATE BAND CLAIM - IHTA 1984 s.8A. Section 8A of the Inheritance Tax Act 1984 permits the unused proportion of the Nil Rate Band from a predeceased spouse or civil partner to be transferred to the surviving spouse's estate at the rate prevailing at the surviving spouse's death.

Predeceased spouse / civil partner: Edward John Whitmore
Date of death of predeceased spouse: 26 September 2014
NRB used on first death: GBP 0
Unused NRB transferable: 100% of the Nil Rate Band prevailing at the surviving spouse's death

Form IHT402 (Claim to transfer unused Nil Rate Band) is filed alongside the IHT400 - the claim is supported by the predeceased spouse's death certificate, marriage certificate, probate grant (if any) and a copy of the IHT account or estate accounts for the first estate.

Combined NRB after TNRB: the surviving spouse's NRB plus the transferred percentage; the combined maximum where 100% TNRB is claimed is twice the prevailing NRB. The TNRB sits behind the surviving spouse's available NRB and is allocated against the chargeable transfers on the death estate.

Re Smith [2017] EWHC 2071 (Ch) confirms that the TNRB transfer is available even where the first death was decades earlier, subject to documentary evidence of the first estate disposition.

TNRB narrative:
Edward John Whitmore (the deceased's late husband) died on 26 September 2014. His entire estate passed to Margaret Anne Whitmore under his will dated 14 May 2012 (a mirror will). Edward's estate was within the IHT spouse exemption (s.18 IHTA 1984) and no IHT was payable; his NRB was 100% unused. The personal representatives accordingly claim a 100% transferable Nil Rate Band on Form IHT402, supported by Edward's death certificate, marriage certificate, grant of probate dated 18 November 2014 and the IHT205 returned at the time. The combined NRB available to Margaret's estate is therefore GBP 650,000 (GBP 325,000 own + GBP 325,000 transferred).
7. RESIDENCE NIL RATE BAND + DOWNSIZING - IHTA 1984 s.8D-s.8M + s.8FA. Sections 8D to 8M of the Inheritance Tax Act 1984 provide an additional Residence Nil Rate Band where a qualifying residential interest is closely inherited by direct descendants (children, grandchildren, step-children, foster children, adopted children, including in trust). The RNRB for 2026/27 is GBP 175,000 per individual.

Qualifying status: a QUALIFYING RESIDENTIAL INTEREST is closely inherited by direct descendants - the full RNRB applies (subject to taper above the GBP 2,000,000 estate threshold).
Qualifying residential interest: 24 Beechwood Drive, Harrogate, North Yorkshire HG2 8QL (the deceased's sole and main residence at the date of death, valued at GBP 685,000)
RNRB amount claimed: GBP 175,000
Downsizing addition claimed (s.8FA): GBP 0

Taper above GBP 2,000,000 estate. Where the net estate exceeds GBP 2,000,000, the RNRB is tapered at the rate of GBP 1 reduction per GBP 2 of excess. The taper does NOT apply on the facts here - the net estate is at or below GBP 2,000,000 and the full RNRB allowance is available.

The Upper Tribunal in HMRC v Hood (Personal Representatives) [2018] UKUT 0420 (TCC) confirmed the strict mathematical operation of the taper above the GBP 2 million threshold and the requirement to apply it before the RNRB allocation against chargeable transfers.

Form IHT435 (Claim for Residence Nil Rate Band) is filed alongside the IHT400 - the claim is supported by the title documents and the closely-inherited beneficiary evidence.
Form IHT436 (Claim to transfer unused RNRB) is filed alongside the IHT400 - the predeceased spouse's unused RNRB is claimed.

RNRB narrative:
24 Beechwood Drive (the deceased's sole and main residence) passes under the deceased's will dated 8 November 2017 to her son Christopher James Whitmore and her daughter Sarah Louise Bennett in equal shares as direct descendants under section 8J of IHTA 1984. The Residence Nil Rate Band of GBP 175,000 is therefore available in full. The net estate is GBP 1,685,000 - below the GBP 2,000,000 taper threshold (HMRC v Hood [2018] UKUT 0420 (TCC)) - so the full RNRB applies without reduction. A transferable RNRB claim on Form IHT436 is also made: Edward Whitmore's estate qualified for the RNRB (which was nil for 2014/15) and 100% of his unused RNRB transfers to Margaret's estate at the rate prevailing at her death; the IHT436 claim is supported by the documents lodged with the IHT402.
8. GIFTS WITH RESERVATION OF BENEFIT - FINANCE ACT 1986 s.102 + FA 2004 SCHEDULE 15 (POAT). Section 102 of the Finance Act 1986 treats a gift as part of the donor's estate at death where the donor reserved a benefit in the subject matter of the gift at any time in the seven years before death. The reservation-of-benefit treatment overrides the seven-year potentially exempt transfer rule.

Gift with reservation present: NO - no gift with reservation of benefit is present in the deceased's lifetime gift pattern.

GWR asset value brought into the death estate: GBP 0
Pre-Owned Asset Tax (POAT) under FA 2004 Schedule 15: POAT does NOT apply on the facts here.

Banks v IRC [2010] EWHC 269 (Ch) confirms the operation of the s.102 reservation-of-benefit test - the question is whether the donor retained an enjoyment of the subject matter at the moment of death. The High Court emphasised the practical effect of the retained benefit rather than the formal legal mechanism.

Allnatt London Properties v IRC [1994] STC 327 provides the valuation methodology for quoted shares (mid-market quarter-up rule) and unquoted shares (open-market expected price) where the GWR asset is a shareholding.

GWR / POAT narrative:
The personal representatives confirm, having reviewed the deceased's bank statements, conveyancing history and lifetime gift records for the seven years before death, that no gift with reservation of benefit under s.102 of the Finance Act 1986 is present in the estate. The deceased remained at 24 Beechwood Drive in her own name throughout and did not transfer ownership of any asset to a relative while continuing to enjoy it. The deceased's 2022 gift of GBP 100,000 to her grandson Oliver Bennett for his university fees was an outright gift with no retained benefit and is treated as a Potentially Exempt Transfer under s.3A IHTA 1984 (see clause 9 below). Banks v IRC [2010] EWHC 269 (Ch) and Allnatt London Properties v IRC [1994] STC 327 reviewed for completeness.
9. LIFETIME POTENTIALLY EXEMPT TRANSFERS - IHTA 1984 s.3A. Section 3A of the Inheritance Tax Act 1984 treats a lifetime gift to an individual as a Potentially Exempt Transfer (PET). A PET becomes chargeable only if the donor dies within seven years of the gift; where the donor survives seven years, the PET drops out of the IHT computation entirely.

Total lifetime gifts in the seven years before death: GBP 143,500
Failed PETs added to the death estate: GBP 143,500

Seven-year tapering relief: Where the donor died between three and seven years after the gift, the IHT due on the failed PET is tapered as follows: 3-4 years (20% relief); 4-5 years (40%); 5-6 years (60%); 6-7 years (80%). Tapering relief applies on the facts here - one or more failed PETs falls within the 3-7 year window and the tapered rate is applied in the calculation.

Aggregation order: Failed PETs are aggregated chronologically (earliest first) and absorb the NRB before the death estate; the death estate bears IHT on any chargeable transfers above the NRB after PET absorption.

Form IHT403 (Gifts and other transfers of value) is filed alongside the IHT400 - the schedule lists each gift, the date, the donee, the value and the exemption claimed.

PET narrative:
The Form IHT403 schedule sets out three lifetime gifts in the seven years before death: (i) GBP 100,000 to Oliver Bennett on 14 May 2022 (within the 3-4 year window - 20% taper); (ii) GBP 25,000 to the Harrogate Hospice on 10 October 2024 (chargeable under s.23 - exempt charity transfer; no PET treatment); (iii) GBP 18,500 to Sarah Louise Bennett on 22 March 2025 (within the 0-3 year window - no taper). The total failed PETs aggregated to the death estate is GBP 118,500 (GBP 100,000 + GBP 18,500); the GBP 25,000 charity gift is exempt and does not aggregate. The aggregation order is chronological - the GBP 100,000 May 2022 gift absorbs NRB first, then the GBP 18,500 March 2025 gift. After absorption the death estate bears IHT at 40% on the excess above the combined NRB + RNRB available (s.7 IHTA 1984).
10. STATEMENT OF TRUTH. I confirm that the information set out in this Form IHT421 is true and correct to the best of my knowledge and belief. I am aware that proceedings for the recovery of unpaid Inheritance Tax may be brought against any personal representative who delivers an incorrect or incomplete IHT account, and that interest accrues from the six-month payment deadline (IHTA 1984 s.233). I confirm that the Form IHT400 has been delivered to HMRC and the IHT due (if any) on the first instalment has been paid.
PERSONAL REPRESENTATIVE
Christopher James Whitmore
executor named in the deceased's will — 8 June 2026
Date: ____________________

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What Is Form IHT421?

Form IHT421 is the United Kingdom Inheritance Tax probate summary. It is the HMRC handover document that releases IHT clearance to the Probate Registry so the Grant of Probate or Letters of Administration can be issued. The form summarises the IHT400 — gross estate value, net estate value, Net Qualifying Value, IHT due, instalment option and personal representative declaration. The IHT421 follows Form IHT400 (or Form C1 confirmation in Scotland; the Northern Ireland HMRC route applies in NI). Roughly 27,000 IHT421s are filed each year, mirroring the IHT400 count, against approximately 250,000 probate grants total per year in England and Wales.

The Probate Registry will not issue the Grant of Probate or Letters of Administration without the IHT421 (or a confirmation that the estate is excepted under the Inheritance Tax (Delivery of Accounts) (Excepted Estates) Regulations 2004). The Net Qualifying Value on the IHT421 drives the Probate Registry application fee under the Probate Registry fees regulations 2022 — the NQV is the estate value passing through the grant after deducting the IHT-exempt portions (spouse exemption under IHTA 1984 s.18; charity exemption under s.23). The NQV is typically lower than the Net Value because the spouse exemption removes the marital share where the surviving spouse inherits.

The 2026/27 Inheritance Tax framework (frozen until April 2031 per the November 2025 Reeves Budget) provides: Nil Rate Band GBP 325,000 per person under IHTA 1984 s.7; Residence Nil Rate Band GBP 175,000 under s.8D-8M where a qualifying residential interest is closely inherited by direct descendants; RNRB taper (GBP 1 reduction per GBP 2 over GBP 2,000,000 estate, per HMRC v Hood [2018] UKUT 0420 (TCC)); Transferable Nil Rate Band under s.8A from a predeceased spouse; standard IHT rate 40% (reduced to 36% under Schedule 1A where 10%+ of the baseline goes to charity); spouse / civil partner exemption under s.18. The Finance Act 2025/2026 BPR and APR reform effective 6 April 2026 introduces a GBP 2,500,000 combined APR/BPR allowance with 50% relief above.

What's Covered in This Template

Our United Kingdom Form IHT421 template builds a structured probate summary the HMRC Inheritance Tax office can clear and the Probate Registry can act on — deceased identification, IHT reference, personal representative details, gross / net estate values, instalment option, and four Expert clauses on the TNRB, RNRB taper, gift with reservation and seven-year PET tapering.

IHT400 → IHT421 → Probate Registry Pipeline

IHT421 is the bridge document. After HMRC processes the IHT400 (the full account) and issues clearance (typically 12-20 weeks), the IHT421 is released to the Probate Registry. The Probate Registry then issues the Grant of Probate or Letters of Administration in England and Wales.

Net Qualifying Value Calculation

The NQV is the estate value passing through the grant after the IHT-exempt portions are removed (spouse exemption under IHTA 1984 s.18; charity exemption under s.23). The NQV drives the Probate Registry application fee under the Probate Registry fees regulations 2022.

Maximum Four Personal Representatives

Rule 20 of the Non-Contentious Probate Rules 1987 (SI 1987/2024) limits a grant to a maximum of four personal representatives. Where the will names more than four executors, the surplus executors have power reserved; a reserved executor may apply for a fresh grant later in the United Kingdom.

Six-Month IHT Payment Deadline + s.227 Instalment Option

IHT is payable within six months from the end of the month of death under IHTA 1984 s.226; interest accrues from that date under s.233. IHT on land, controlling shareholdings, business or partnership interests can be paid by ten annual instalments under s.227-234 (first instalment due on the six-month deadline).

TNRB — IHTA 1984 s.8A Predeceased Spouse (Expert)

Expert clause structures the Transferable Nil Rate Band under IHTA 1984 s.8A — the surviving spouse can claim up to 100% of the predeceased spouse's unused Nil Rate Band on Form IHT402. The TNRB applies at the NRB rate prevailing at the surviving spouse's death, doubling the available NRB up to GBP 650,000 for couples.

RNRB Taper — HMRC v Hood [2018] UKUT 0420 (TCC) (Expert)

Expert clause covers the Residence Nil Rate Band GBP 175,000 under IHTA 1984 s.8D-8M and the taper above GBP 2,000,000 estate (HMRC v Hood (Personal Representatives) [2018] UKUT 0420 (TCC)). RNRB is lost GBP 1 for every GBP 2 of estate value over GBP 2m. Downsizing addition under s.8FA where the deceased downsized before death.

Gift with Reservation — FA 1986 s.102 + Banks v IRC (Expert)

Expert clause structures the GWR analysis under Finance Act 1986 s.102. Where the deceased made a lifetime gift but retained a benefit (e.g. continued to live in the gifted house), s.102 treats the gifted asset as part of the death estate. Cites Banks v IRC [2010] EWHC 269 (Ch) on the leading authority; FA 2004 Schedule 15 Pre-Owned Asset Tax as the income tax alternative.

Seven-Year PET Tapering — IHTA 1984 s.3A (Expert)

Expert clause covers Potentially Exempt Transfers under IHTA 1984 s.3A. If the donor survives seven years, the PET drops out of the IHT computation. If the donor dies within seven years, the PET fails and is aggregated with the death estate; tapering applies between 3-7 years (20% / 40% / 60% / 80% off the failed-PET tax). Reported on Form IHT403.

Executor vs Administrator Type Switch

Auto-switches the wording based on the personal representative type — executor (testate, applying for Grant of Probate via PA1P route under the Senior Courts Act 1981 s.114), administrator (intestate, applying for Letters of Administration via PA1A under the Administration of Estates Act 1925), or administrator with will annexed.

IHTA 1984 s.267 Deemed Domicile Coverage

For estates with foreign domicile elements, the template flags the deemed United Kingdom domicile rule under IHTA 1984 s.267 — 15 of the last 20 tax years UK resident, or domicile of choice within three years of death. Deemed domicile triggers full UK IHT400 / IHT421 treatment on the worldwide estate.

CTC vs DPR vs PSC Filing Route

Pre-frames the United Kingdom filing route — Courts and Tribunals Service Centre (CTC) for online applications via GOV.UK Apply for Probate; District Probate Registry (DPR) for paper applications, complex estates and contested cases; Probate Service Centres (PSC) at Blackpool, Manchester and Newcastle for paper processing.

Personal Representative Declaration + IHTA s.247

Pre-drafts the personal representative declaration. The PR is personally liable for inaccurate or fraudulent declarations under Finance Act 2007 Schedule 24 (up to 30% careless, 70% deliberate, 100% concealment). Criminal sanction under IHTA 1984 s.247 for fraudulent information.

How to Complete Form IHT421

Follow these steps to produce a well-structured United Kingdom Form IHT421 probate summary for the HMRC handover to the Probate Registry.

  1. 1

    Confirm Domicile and Jurisdiction

    IHT421 covers England and Wales only. Scottish estates use Form C1 confirmation instead; Northern Ireland uses the HMRC NI route. Foreign domicile may still trigger deemed UK domicile under IHTA 1984 s.267 (15 of the last 20 tax years UK resident, or domicile of choice within 3 years of death) — IHT400 / IHT421 then applies on the worldwide estate.

  2. 2

    Capture the IHT Reference and IHT400 Linkage

    HMRC issues the IHT reference when the IHT400 is filed (or, on request, in advance for direct payment scheme purposes). The reference is printed on the IHT400 acknowledgment letter and is needed on every piece of correspondence with HMRC and the Probate Registry. The IHT421 captures the IHT400 box 99 / 109 (gross) and box 100 / 110 (net) values.

  3. 3

    Identify the Personal Representative(s)

    An executor is appointed by the will and applies for a Grant of Probate (PA1P route). An administrator is appointed where there is no valid executor (intestacy, executor renunciation, or no executor named) and applies for Letters of Administration (PA1A route). An administrator with will annexed applies where there is a will but no executor able or willing to act. Maximum four under NCPR 1987 rule 20.

  4. 4

    Enter the Gross Estate Value

    The gross value is the total open-market value of all assets in the estate before deduction of any debts, funeral expenses or exemptions. It is the figure carried forward from box 99 / box 109 of the IHT400. Gross estate includes property at probate value (Land Registry / RICS valuation), bank balances at date of death, share registrar statements and chattels.

  5. 5

    Enter the Net Estate Value

    The net value is the gross value less debts and funeral expenses but before exemptions (spouse, charity). It is the figure carried forward from box 100 / box 110 of the IHT400. Debts include mortgages, credit cards, loans, unpaid utilities and reasonable funeral expenses (typically capped at GBP 5,000).

  6. 6

    Calculate the Net Qualifying Value (NQV)

    The NQV is the value passing through the grant after IHT-exempt portions are removed — spouse exemption under IHTA 1984 s.18 and charity exemption under s.23. The NQV drives the Probate Registry application fee under the Probate Registry fees regulations 2022. NQV is typically lower than Net Value where the surviving spouse inherits and the spouse exemption applies.

  7. 7

    Pick the Instalment Option Where Applicable

    IHT on land, controlling shareholdings, business or partnership interests can be paid by ten annual instalments under IHTA 1984 s.227-234. The first instalment is due six months from the end of the month of death; interest accrues on the deferred instalments. The instalment option helps personal representatives manage cashflow during estate administration in the United Kingdom.

  8. 8

    Plead the TNRB and RNRB Where Available (Expert)

    Expert clauses structure the Transferable Nil Rate Band under IHTA 1984 s.8A (up to 100% of the predeceased spouse's unused NRB on Form IHT402) and the Residence Nil Rate Band under s.8D-8M (GBP 175,000 where a qualifying residential interest is closely inherited; tapered above GBP 2m estate per HMRC v Hood [2018] UKUT 0420 (TCC)).

  9. 9

    Address Gifts with Reservation and Failed PETs (Expert)

    Expert clause structures the GWR analysis under FA 1986 s.102 (citing Banks v IRC [2010] EWHC 269 (Ch)) and the failed-PET position under IHTA 1984 s.3A. Where the deceased made lifetime gifts in the seven years before death, the failed-PET tax is computed with tapering (20% / 40% / 60% / 80% off between years 3-7) on Form IHT403.

  10. 10

    Sign the Personal Representative Declaration and File

    The personal representative signs the declaration. The PR is personally liable for inaccurate or fraudulent declarations under Finance Act 2007 Schedule 24; criminal sanction under IHTA 1984 s.247 applies. File via the CTC (online GOV.UK Apply for Probate), the DPR (paper) or the PSC (paper processing centre at Blackpool, Manchester or Newcastle) in the United Kingdom.

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Legal Considerations — Form IHT421 Probate Summary

Inheritance Tax in the United Kingdom is governed by the Inheritance Tax Act 1984 (IHTA 1984), the IHT (Delivery of Accounts) (Excepted Estates) Regulations 2004 and the Finance Act 2008 Schedule 36 (late filing penalties). Probate procedure is governed by the Non-Contentious Probate Rules 1987 (SI 1987/2024); jurisdiction-specific rules apply in Scotland (Form C1 confirmation) and Northern Ireland (HMRC NI route).

This template is for general information and does not constitute legal advice. Inheritance Tax involves substantive law on domicile, valuation, reliefs, exemptions and trust interests. A solicitor or tax adviser specialising in private client work is recommended for any estate above the IHT threshold, any estate claiming BPR / APR (especially under the Finance Act 2025/2026 reform effective 6 April 2026), any estate with foreign assets and any estate where the Transferable Nil Rate Band is contested. The Society of Trust and Estate Practitioners (STEP) maintains a directory of qualified practitioners; the Chartered Institute of Taxation (CIOT) Inheritance Tax sub-committee provides specialist resources.

Reviewed for the United Kingdom (England and Wales)

IHT421 in the IHT400 → Probate Registry Pipeline

IHT421 is the bridge document. After HMRC processes the IHT400 (the full Inheritance Tax account) and issues clearance (typically 12-20 weeks), the IHT421 is released to the Probate Registry. The Probate Registry then issues the Grant of Probate (testate, under the Senior Courts Act 1981 s.114) or Letters of Administration (intestate, under the Administration of Estates Act 1925). The Probate Registry will not issue a grant without IHT clearance (or excepted-estate confirmation under the IHT (Delivery of Accounts) (Excepted Estates) Regulations 2004).

IHT Framework 2026/27

The 2026/27 IHT thresholds (frozen until April 2031 per the November 2025 Reeves Budget) provide: Nil Rate Band GBP 325,000 (IHTA s.7); Residence Nil Rate Band GBP 175,000 (s.8D-8M, qualifying home closely inherited by direct descendants); RNRB taper (GBP 1 reduction per GBP 2 over GBP 2,000,000 estate, per HMRC v Hood [2018] UKUT 0420 (TCC)); Downsizing Allowance (s.8FA); Transferable Nil Rate Band (s.8A, unused NRB from predeceased spouse, up to 100%); transferable RNRB (s.8G); standard rate 40% (36% where 10%+ of baseline goes to charity, Schedule 1A); spouse / civil partner exemption under s.18. Combined-couple maximum up to GBP 1,000,000 where both NRB + RNRB transfer in full.

Reservation of Benefit — FA 1986 s.102 + Banks v IRC

Where the deceased made a lifetime gift but retained a benefit (e.g. continued to live in the house gifted to children), Finance Act 1986 s.102 treats the gifted asset as part of the death estate for IHT purposes. The leading authority is Banks v IRC [2010] EWHC 269 (Ch); valuation of shares brought into the GWR pool follows Allnatt London Properties v IRC [1994] STC 327. The Pre-Owned Asset Tax route under FA 2004 Schedule 15 is the income tax alternative regime — the deceased's lifetime income tax was charged on the deemed annual value of the retained benefit. The two regimes are alternatives, not cumulative.

Failed PETs and Seven-Year Tapering

Potentially Exempt Transfers under IHTA 1984 s.3A are lifetime gifts to individuals. If the donor survives seven years from the date of the gift, the PET drops out of the IHT computation entirely. If the donor dies within seven years, the PET fails and is aggregated with the death estate. Tapering relief applies between years 3-7 of the failed-PET schedule: 20% off the failed-PET tax at year 3-4, 40% at 4-5, 60% at 5-6, 80% at 6-7. The schedule is reported on Form IHT403. NRB is consumed by the earliest gifts first, so the most recent PETs typically attract the full failed-PET charge.

Frequently Asked Questions

Build Your Form IHT421 Probate Summary

Produce a structured United Kingdom Form IHT421 probate summary the HMRC Inheritance Tax office can clear and the Probate Registry can act on — deceased identification, IHT reference, personal representative type (executor or administrator), gross estate value (IHT400 box 99 / 109), net estate value (box 100 / 110), Net Qualifying Value driving the Probate Registry fee, six-month IHT payment deadline under IHTA 1984 s.226 with the s.227 instalment option on land and qualifying shares, and four Expert clauses on the Transferable Nil Rate Band under s.8A, the RNRB taper under s.8D-8M (HMRC v Hood [2018] UKUT 0420 (TCC)), gift with reservation under FA 1986 s.102 (Banks v IRC) and the seven-year PET tapering schedule under s.3A.

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