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Inheritance Tax Planning

Spousal Exemption
and Inheritance Tax

Assets passed to a surviving spouse or civil partner are completely exempt from Inheritance Tax — with no upper limit. Understand how the exemption works, what common law partners miss out on, and how to maximise your combined allowances.

Unlimited

Spousal Exemption

No upper limit on assets passed to a UK-domiciled spouse or civil partner.

£325,000

Standard Nil-Rate Band

Each individual's tax-free threshold — frozen since 2009.

£650,000

Couples' Combined Threshold

Transferable nil-rate band doubles the tax-free amount for surviving spouses.

£1,000,000

With Residence NRB

Couples leaving their home to direct descendants can shelter up to £1 million.

What Is the Spousal Exemption?

The spousal exemption is one of the most powerful reliefs in UK Inheritance Tax law. Under section 18 of the Inheritance Tax Act 1984, transfers of assets between spouses and civil partners — whether on death or during lifetime — are completely exempt from IHT, provided both parties are UK-domiciled.

There is no upper limit. A £5 million estate left entirely to a surviving spouse attracts zero Inheritance Tax. This is fundamentally different from gifts to children or other beneficiaries, which are subject to the 40% rate on amounts above the nil-rate band.

The exemption applies equally to married couples and civil partners. It does not apply to cohabiting couples — sometimes called common law partners — regardless of how long they have lived together.

Common Law Partners Are Not Protected

Cohabiting couples have no automatic IHT exemption. If you are not married or in a civil partnership, assets left to your partner will be subject to IHT at 40% on amounts above £325,000. Marriage or civil partnership is the only way to access the spousal exemption.

How the Spousal Exemption Works

1

Unlimited Exemption on Death

When you die, any assets you leave to your spouse or civil partner pass completely free of Inheritance Tax — regardless of the value. There is no cap. A £2 million estate left entirely to a spouse attracts zero IHT.

2

Lifetime Transfers Are Also Exempt

Transfers between spouses during your lifetime are also immediately exempt from IHT. Unlike gifts to other people — which require you to survive seven years — interspousal transfers are exempt from the moment they are made.

3

Unused Nil-Rate Band Is Transferred

If the first spouse to die does not use all of their nil-rate band (for example, because they left everything to the survivor), the unused percentage is transferred to the surviving spouse's estate — effectively doubling the tax-free threshold to £650,000.

4

Residence Nil-Rate Band Is Also Transferable

The Residence Nil-Rate Band (RNRB) of up to £175,000 — which applies when leaving a main home to direct descendants — is also transferable between spouses. This means couples can shelter up to £1 million from IHT.

Married Couples vs Common Law Partners: IHT Comparison

The difference in IHT treatment between married couples and cohabiting partners is stark.

IssueMarried / Civil PartnersCommon Law Partners
IHT on assets at death0% — unlimited exemption40% on amounts above £325,000
Lifetime transfersImmediately exemptSubject to 7-year rule (PETs)
Transferable nil-rate bandYes — up to £325,000 extraNot available
Transferable RNRBYes — up to £175,000 extraNot available
Combined tax-free thresholdUp to £1,000,000£325,000 only
Non-UK domiciled spouseLimited exemption (£325,000) unless electing UK domicileN/A

Non-UK Domiciled Spouses

The unlimited spousal exemption applies only where both spouses are UK-domiciled. If your spouse is not UK-domiciled, the exemption is capped at £325,000 — the same as the standard nil-rate band.

  • If your spouse is not UK-domiciled, the unlimited spousal exemption does not apply in full.
  • The exemption is capped at £325,000 for transfers to a non-UK domiciled spouse.
  • A non-UK domiciled spouse can elect to be treated as UK-domiciled for IHT purposes — but this election has wider tax implications and should be considered carefully.
  • If you are not UK-domiciled yourself, IHT applies only to your UK assets — not your worldwide estate.
  • Domicile is a complex legal concept distinct from residence or nationality. Professional advice is essential.

Planning Strategies for Married Couples

The spousal exemption defers IHT — it does not eliminate it. These strategies help reduce the bill on the second death.

Do Not Rely on the Exemption Alone

Leaving everything to your spouse defers the IHT problem — it does not eliminate it. On the second death, the full combined estate is assessed. Without planning, a large estate can face a significant IHT bill.

Use Both Nil-Rate Bands

Consider leaving assets up to the nil-rate band (£325,000) to children or a trust on first death, rather than everything to the spouse. This uses the first nil-rate band immediately rather than relying on the transfer mechanism.

Consider a Protective Property Trust

A Protective Property Trust in your will can protect your share of the family home while still allowing your spouse to live there for life. This preserves your nil-rate band and protects the property from care fees and remarriage risks.

Keep Records of the First Death

To claim the transferable nil-rate band on the second death, executors must submit forms IHT400 and IHT402 with evidence of the first spouse's estate. Keep marriage certificates, wills, and grant of probate documents safely.

Review After Remarriage

If you remarry after being widowed, the transferable nil-rate band from your first spouse is not lost — but your estate planning should be reviewed to ensure it still achieves your goals.

Use a Deed of Variation

If the first spouse's will did not maximise the nil-rate band, a Deed of Variation can redirect assets within two years of death to preserve the allowance and reduce the eventual IHT bill.

Frequently Asked Questions

Is there a limit on the spousal exemption for Inheritance Tax?

No — there is no upper limit on the spousal exemption, provided both spouses are UK-domiciled. Assets of any value can pass between spouses or civil partners completely free of IHT.

Does the spousal exemption apply to civil partners?

Yes. Civil partners have exactly the same IHT protections as married couples. The unlimited spousal exemption, the transferable nil-rate band, and the transferable Residence Nil-Rate Band all apply equally.

Do common law partners get the spousal exemption?

No. Common law partners — couples who live together but are not married or in a civil partnership — do not qualify for the spousal exemption. Assets left to a common law partner are subject to IHT at 40% on amounts above £325,000.

What happens to the nil-rate band if I leave everything to my spouse?

If you leave everything to your spouse, your nil-rate band is unused. The unused percentage is transferred to your spouse's estate and can be claimed on the second death — effectively doubling the tax-free threshold to £650,000.

What is the Residence Nil-Rate Band and is it transferable?

The Residence Nil-Rate Band (RNRB) is an additional £175,000 allowance that applies when you leave your main home to direct descendants (children, stepchildren, grandchildren). It is transferable between spouses in the same way as the standard nil-rate band, allowing couples to shelter up to £1 million from IHT.

What if my spouse is not UK-domiciled?

If your spouse is not UK-domiciled, the unlimited spousal exemption does not apply in full. The exemption is capped at £325,000. Your spouse can elect to be treated as UK-domiciled for IHT purposes, but this has wider tax implications and requires careful advice.

Are lifetime gifts to a spouse exempt from IHT?

Yes. Transfers between spouses during your lifetime are immediately exempt from IHT — unlike gifts to other people, which require you to survive seven years to become fully exempt.

Should I leave everything to my spouse to avoid IHT?

Leaving everything to your spouse defers the IHT problem rather than eliminating it. On the second death, the full combined estate is assessed. Careful planning — including the use of trusts and both nil-rate bands — can significantly reduce the eventual bill.

What is a Deed of Variation and how does it help?

A Deed of Variation allows beneficiaries to redirect their inheritance within two years of death. If the first spouse's will did not make optimal use of the nil-rate band, a Deed of Variation can redirect assets to preserve the allowance and reduce the IHT bill on the second death.

How do I claim the transferable nil-rate band?

Executors of the second spouse's estate must actively claim the transferable nil-rate band by submitting forms IHT400 and IHT402 to HMRC, along with supporting documents including the marriage certificate, the first spouse's will, and the grant of probate. The claim must be made within 24 months of the second death.

Make the Most of Your Spousal Exemption

The spousal exemption is a powerful tool — but it works best as part of a wider estate plan. Our wills and estate planning solicitors in Chester can help you structure your estate to minimise IHT for the next generation.

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