HMRC Technical Consultation on IHT on Pensions

ShareSoc responds to the Chancellor’s proposals on the application of IHT to residual pensions. 

Following the budget last autumn, HMRC launched a technical consultation on the implementation of the Chancellor’s proposals to apply inheritance tax (IHT) to unused pensions, upon the death of the pension beneficiary.

Note that the consultation explicitly states:

As announced at Autumn Budget 2024, from 6 April 2027 most unused pension funds and death benefits will be included within the value of a person’s estate for Inheritance Tax purposes and pension scheme administrators will become liable for reporting and paying any Inheritance Tax due on pensions to HMRC. This consultation seeks views on the processes required to implement these changes.

Fortunately, Paul Greenwood, a volunteer member of ShareSoc’s policy committee, is an expert on such matters, as he is a former chair of the Association of Consulting Actuaries Pensions scheme committee.

ShareSoc has submitted this response, drafted by Paul and approved by our policy committee, which points out the many problems with the original proposals, particularly concerning estate administration and issues for pension trustees.

We advocate that if the government wishes to impose a tax on unused pensions, this should be a discrete tax, separate from IHT, that would claw back tax relief on contributions and gains, at a standardised rate of, say, 35%.

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