IHTM06023 | Rules about excepted estates: what is not an excepted estate

From HM Revenue & Customs · Inheritance Tax Manual

There are instances when an estate cannot qualify as an excepted estate, regardless of the value. These are:

Where the deceased held an interest in possession () in more than one item of settled property ().

For deaths from 1 September 2006 to 5 April 2011, where a charge arises under -C (Inheritance Tax (IHT) charge on an alternatively secured pension fund).

Where, on or after 18 March 1986, the deceased made a gift with reservation of benefit and either:

  • the reservation still subsists at the death (), or

  • the property ceased to be subject to the reservation within the seven years before the death - unless this constituted a specified transfer ().

Where the deceased has elected that property should be treated as part of their estate for IHT rather than pay a pre-owned asset charge,

Where, for deaths before 6 April 2025, the deceased is regarded as deemed domiciled () in the UK under the provisions of .