A strategic briefing for advisers navigating the post-reform landscape

Inheritance Tax planning has historically followed a relatively stable logic.

• Pensions sat outside the estate.
• Business and agricultural assets benefited from full relief.
• Thresholds were predictable.

That stability is changing.

With residence-based IHT rules now in force, relief reforms underway, pensions expected to fall within estates from April 2027, and thresholds frozen until 2030, advisers are operating in a structurally different planning environment.

This is not simply about new tax rules. It is about how advisers must adapt their approach to estate strategy.

Many of these themes were explored in greater depth during our February 2026 professional webinar, where Steve Gauke was joined by probate specialist Paul Radcliffe and financial planner George Davey to discuss the practical implications for advisers.

Watch the February 2026 webinar discussion

1. Residence-based taxation – reassessing international exposure

The shift from domicile-based to residence-based IHT fundamentally alters exposure for internationally mobile clients.

Individuals who have been UK resident for 10 of the last 20 years may bring worldwide assets within scope.

Strategically, advisers should:

• Review internationally mobile client files
• Revisit trust planning assumptions
• Assess timing of asset disposals
• Consider the position of returning expatriates

This is not simply a compliance update. It may materially alter estate projections and long-term planning outcomes.

2. Relief reform – modelling partial exposure

Changes to Agricultural Property Relief (APR), Business Property Relief (BPR), and AIM relief reduce certainty for business-owning families.

Relief may still apply, but in capped or reduced form.

Strategically, advisers should now:

• Model partial relief outcomes
• Stress-test succession plans
• Reassess estate value forecasts
• Consider phased lifetime mitigation strategies

Clients who previously relied on full relief assumptions may now face exposure they had not anticipated.

3. Pensions from April 2027 – a sequencing reset

If pensions fall within the estate for IHT purposes from April 2027, the traditional sequencing strategy of preserving pension assets until last will require review.

This change affects not only tax mitigation, but retirement income planning and intergenerational wealth transfer.

Advisers may need to reconsider:

• Order of asset drawdown
• Use of tax-free cash
• Gifting from excess income
• Protection-based funding structures
• Estate modelling assumptions

Clients who believed their estate exposure was controlled may find projections materially altered.

This is not a minor technical adjustment. It is a sequencing rethink.

4. Fiscal drag – the expanding tax base

Frozen IHT thresholds until 2030 create gradual expansion of liability.

Property values, business valuations and investment portfolios may increase, while allowances remain static.

Advisers should:

• Run forward projections under conservative growth assumptions
• Identify clients approaching exposure thresholds
• Embed estate reviews into regular planning cycles

In many cases, today’s non-taxable estate may become tomorrow’s taxable one.

5. Probate reality in a reform environment

Legislative reform increases planning complexity.

Probate administration adds practical pressure.

Inheritance Tax generally needs to be addressed before probate is granted.

Where estates are property-heavy or business-heavy, liquidity planning becomes essential.

Key strategic questions for advisers include:

• How will IHT be paid?
• What assets are accessible pre-grant?
• Are financial institutions participating in the direct payment scheme?
• Would HMRC instalment arrangements be viable?

Liquidity is no longer a secondary issue. It is part of reform-aware estate planning.

6. Where structured estate funding may fit

In some estates, reform and probate timing converge to create temporary funding gaps.

Where Inheritance Tax is due and estate liquidity is constrained, structured estate funding – such as an estate advance – may provide certainty and speed.

Similarly, where beneficiaries face personal cashflow pressure during probate, early-access funding may relieve financial strain.

These facilities are not universal solutions. They form part of a broader toolkit that should be considered alongside HMRC arrangements and asset realisation strategies.

The adviser’s responsibility is not to promote one route, but to ensure the full range of options is clearly explained and assessed for suitability.

7. The adviser’s role – from planner to coordinator

The cumulative effect of:
Residence-based taxation

• Relief reform
• Pension inclusion
• Frozen thresholds

requires more than technical competence.

It requires coordination.

Advisers who add the greatest value will:

• Encourage structured will review cycles
• Involve next-generation beneficiaries appropriately
• Coordinate effectively with solicitors and probate specialists
• Model post-reform exposure under multiple scenarios
• Recognise potential vulnerability at bereavement

Estate planning in this environment is no longer solely about minimising tax.

It is about preparedness.

A strategic reset

Taken together, recent reforms represent a structural shift rather than incremental adjustment.

Advisers who treat each change in isolation may underestimate their combined effect.

Those who adopt a strategic, review-led approach – integrating tax modelling, sequencing analysis, liquidity preparedness and professional collaboration – will be better positioned to protect client outcomes.

Inheritance Tax reform is not simply legislative change.

It is a planning environment reset.

If you would like to discuss how estate advances or Inheritance Advances may sit within your wider post-reform strategy, the Provira partnerships team is available to provide case-specific guidance.