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Contents

Official guidance
Inheritance Tax Manual

IHTM46000 · Residence nil rate band

  • IHTM46001 · Basic Principles: general overview
  • IHTM46002 · Basic Principles: phasing-in RNRB
  • IHTM46003 · Basic Principles: how the RNRB is applied.
  • IHTM46004 · Basic principles: claims
  • IHTM46010 · Basic definitions: introduction
  • IHTM46011 · Basic Definitions: ‘Qualifying Residential Interest’ and ‘Residential Property Interests’
  • IHTM46012 · Basic definitions: the value of the estate ‘E’ and the value transferred on death ‘VT’
  • IHTM46013 · Basic definitions: ‘Closely Inherited’
  • IHTM46014 · Basic definitions: 'Inherited'
  • IHTM46020 · Calculating the RNRB: introduction
  • IHTM46021 · Calculating the RNRB: when is RNRB due?
  • IHTM46022 · Calculating the RNRB: terms used: 'residential enhancement'
  • IHTM46023 · Calculating the RNRB: terms used: the 'taper threshold'
  • IHTM46024 · Calculating the RNRB: terms used: the 'default allowance'
  • IHTM46025 · Calculating the RNRB: terms used: the 'adjusted allowance'
  • IHTM46026 · Calculating the RNRB: calculating the 'default allowance' and the 'adjusted allowance'
  • IHTM46027 · Calculating the RNRB: calculating the value of the QRI that is closely inherited
  • IHTM46030 · More detailed guidance: dwelling-house
  • IHTM46031 · More detailed guidance: residence
  • IHTM46032 · More detailed guidance: residence outside the UK
  • IHTM46033 · More detailed guidance: inherited
  • IHTM46034 · More detailed guidance: direct descendants
  • IHTM46040 · Transfer of unused RNRB: the brought-forward allowance
  • IHTM46041 · Transfer of unused RNRB: the brought-forward allowance: method of calculation
  • IHTM46042 · Transfer of unused RNRB: the brought-forward allowance: when and how claims are made
  • ihtm46043 · Transfer of unused RNRB: effect on available RNRB
  • IHTM46044 · Transfer of unused RNRB: effect of tapering
  • IHTM46050 · Downsizing: general principles
  • IHTM46051 · Downsizing: the property disposed of
  • IHTM46052 · Downsizing: the closely inherited property
  • IHTM46053 · Downsizing: qualifying former residential interest (QFRI)
  • IHTM46054 · Downsizing: Disposals: qualifying former residential interest: disposal under contract
  • IHTM46055 · Downsizing: disposals: qualifying former residential interest: interest in possession trust
  • IHTM46056 · Downsizing: disposals: qualifying former residential interest: property subject to a reservation of benefit
  • IHTM46060 · Downsizing Calculations: overview
  • IHTM46061 · Downsizing Calculations: where there is a qualifying residential interest in the estate: conditions
  • IHTM46062 · Downsizing Calculations: where there is a qualifying residential interest in the estate: how to calculate the lost relievable amount
  • IHTM46063 · Downsizing conditions: where there is a qualifying residential interest in the estate: calculating the downsizing addition
  • IHTM46064 · Downsizing calculations: where there is no residential property interest in the estate: conditions
  • IHTM46065 · Downsizing calculations: where there is no residential property interest in the estate: how to calculate the lost relievable amount
  • IHTM46066 · Downsizing calculations: where there is no residential property interest in the estate: calculating the downsizing addition
  • IHTM46067 · Downsizing calculations: interaction with the taper threshold
  • IHTM46070 · Applying the RNRB to the estate: examples
  • IHTM46080 · Estates with conditionally exempt property
  • IHTM46100 · RNRB: glossary of terms
  1. Residence nil rate band: contents
  2. Downsizing: the closely inherited property

IHTM46052 | Downsizing: the closely inherited property

From HM Revenue & Customs · Inheritance Tax Manual

To qualify for a downsizing addition (IHTM46050) not only must there have been a qualifying disposal, or a QFRI (IHTM46053), there must also be property or assets, other than the QRI, which are closely inherited (IHTM46013) on the death. Note, however, that there is no need for the assets which are closely inherited to have any connection to the property which has been disposed of. There is no requirement to trace of any sale proceeds from the disposal.

The downsizing addition can never exceed the value of the other property or assets which are closely inherited.

Example

Emma’s estate includes a residential property interest (IHTM46011) valued at £100,000 and £600,000 of other assets when she dies in May 2019. She leaves £50,000 to her grandchild with the rest of the estate to her niece. The residential enhancement (IHTM46022) at the date of death is £150,000.

The default allowance (IHTM46024) is equal to the residential enhancement, £150,000. The estate is below the taper threshold (IHTM46023) so there is no reduction in the default allowance.

The residential property interest (£100,000) is less than the default allowance (£150,000) so it is possible for a downsizing addition to arise.

There is property other than any QRI which is closely inherited (the £50,000 left to the grandchild), so any downsizing addition would be limited to £50,000.

Whether there is actually any downsizing addition in this case would depend on whether Emma had downsized or disposed of any residential property interest after 8 July 2015 and, if she had, whether this resulted in any RNRB being lost (the ‘lost relievable amount’). The rules around calculating the lost relievable amount are at IHTM46059.

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