Inheritance tax: residence and transferable nil rate bands – part 3

Lisa Macpherson ATT TEP, head of tax technical at PKF Francis Clark, unpicks the complexity of the inheritance tax residence nil rate band (RNRB), transferable nil rate band and compliance issues, with case studies of typical scenarios

This article looks at the inheritance tax (IHT) nil rate bands (NRBs). References to spouses in this article should be taken to include civil partners, and legislative references are to Inheritance Tax Act 1984 (IHTA 1984), unless otherwise indicated. From 13 March 2014, the term spouse includes a same sex spouse following the Marriage (Same Sex Couples) Act 2013.

Residence nil rate band (RNRB)

Instead of running through the residence NRB (RNRB) and transferable RNRB (TRNRB) rules for calculating relief, or who qualifies, the examples below highlight some of the quirks in the rules.

 The RNRB is covered in IHTA 1984, ss8D-8M and is given at the rate of:

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