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    Inheritance Tax Planning

    Flexible Reversionary Trust

    "Know exactly where you stand. Protect the people who matter most."

    Gift capital outside your estate today. Keep the trustees' flexibility to release payments back to you if life changes. Growth sits outside your estate from day one.

    Complete Your Estate Discovery
    Sean Kiani, estate planning adviser at Inheritance Made Simple

    Evidence

    The problem is about to get bigger

    From April 2027, pensions will be brought into the scope of Inheritance Tax. For many families, this will turn a previously tax-efficient asset into one of the largest IHT liabilities in the estate.

    The standard advice has always been to gift assets and wait seven years. That is rigid. If your circumstances change, the money is gone. If you need it back, you are dependent on someone else's goodwill.

    Why the old approach is no longer enough

    • Pension assets become taxable from April 2027
    • Gift-and-wait removes access to your own capital
    • Seven years is a long time for life to change
    • Many families need flexibility, not just tax efficiency

    Understanding

    How a Flexible Reversionary Trust resolves this

    Gift money today

    Move capital outside your estate immediately. The transfer starts the seven-year clock, and growth is outside the estate from day one.

    Retain flexibility

    Trustees have the power to release payments back to you if your circumstances change. You are not locked out of your own capital.

    Built around your life

    The structure is set up to suit your circumstances, not forced into a one-size-fits-all template.

    A Flexible Reversionary Trust is not a loophole. It is a properly constituted trust arrangement that gives trustees discretion to make reversions to the settlor. That discretion is what makes the structure suitable for people who want IHT exposure reduction while retaining a capital route.

    Preparation

    The right structure depends on your circumstances

    Suitability depends on what you own, who you want to protect, whether you may need access to capital, and how the rest of your estate is structured. A Flexible Reversionary Trust is one tool among several.

    The first step is not to choose a product. The first step is to understand the estate: the assets, the people, the liabilities, and the objectives. Only then can the right structure be identified.

    This is typically suitable if you:

    • Want to reduce IHT exposure on capital you can afford to gift
    • Would value a possible route back to the capital later
    • Have a meaningful estate affected by the April 2027 pension changes
    • Are prepared to take regulated advice before proceeding

    FAQs

    Common questions

    A Flexible Reversionary Trust is designed so that trustees can release payments back to you if your circumstances change. The key is that the trust structure is built with that flexibility from the outset, rather than requiring you to give away capital permanently and hope you never need it.

    No. The right structure depends on your estate size, your need for access to capital, your health, your family circumstances and your wider tax position. It is a powerful tool for people who want to reduce inheritance tax exposure while retaining a possible route to capital. It is not suitable where you may need immediate, guaranteed access to the full amount.

    The gift into trust reduces your estate immediately for the purposes of the capital moved. Growth on the trust assets sits outside your estate from day one. The full IHT benefit of the original capital is typically secured after seven years, with taper relief available if death occurs between three and seven years.

    A standard discretionary trust is flexible for beneficiaries but usually requires you to give up capital permanently. A Flexible Reversionary Trust adds a reversionary mechanism, meaning the trustees have the power to return capital to you if needed. That changes the risk profile and makes it suitable for people who want IHT efficiency without total capital lock-in.

    From April 2027, unused pension assets will fall inside the taxable estate. For many families this will be the single largest IHT exposure they have ever faced. A Flexible Reversionary Trust is one of several structures that can help move capital outside the estate before death, reducing the overall liability.

    Next Step

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    This post is for general information only and does not constitute financial or tax advice. Individual circumstances vary, please seek personalised advice.

    Members of the Society of Will Writers|28 years of specialist estate planning practice|Serving families across Dorset, Hampshire and the South of England