Inheritance Tax (IHT) is charged at 40% on the value of a taxable estate above the nil rate band (£325,000 in 2026, plus up to £175,000 residence nil rate band if applicable). For high-net-worth individuals, the potential liability can be hundreds of thousands of pounds or more. Gifting — transferring assets out of the estate during lifetime — is one of the most straightforward and immediate mitigation routes available.
The key to an effective gifting strategy is understanding which gifts fall outside the estate immediately, which require seven years to become fully exempt, and how to combine exemptions to maximise the annual transfer of wealth.
Gifts That Are Immediately Exempt
Several categories of gift escape IHT with no waiting period:
Annual Exemption: £3,000
Every UK individual can gift up to £3,000 per tax year free of IHT. This exemption applies per donor, not per recipient — the £3,000 can be given to one person or split across multiple recipients.
An important feature: unused annual exemption can be carried forward by one year. If you made no gifts in 2024–25, in 2025–26 you can gift up to £6,000 using both years' combined exemption. The carry-forward expires after one year — you cannot accumulate multiple years.
For a married couple, each partner can gift £3,000 per year (£6,000 combined), rising to £12,000 in the year following a year where neither used the exemption.
Small Gifts Exemption: £250
Any number of individuals can receive gifts of up to £250 per person per tax year with no IHT implications. This cannot be combined with the annual exemption for the same recipient — if you are already using your annual exemption on one person, you cannot also give them a £250 small gift in the same year.
This is most useful for Christmas and birthday gifts to grandchildren, nephews, nieces, and others.
Wedding and Civil Partnership Gifts
Gifts in consideration of marriage or civil partnership benefit from fixed exemptions:
- £5,000 from a parent to each child.
- £2,500 from a grandparent (or great-grandparent) to each grandchild.
- £1,000 from anyone else to either party.
These exemptions are per donor, per marriage. They apply only if the gift is made before (not after) the marriage takes place and is conditional on the marriage going ahead.
The Seven-Year Rule: Potentially Exempt Transfers (PETs)
Any gift that does not fall within an immediate exemption is a Potentially Exempt Transfer (PET). A PET is free of IHT if the donor survives for seven years from the date of the gift. If the donor dies within seven years, the gift is brought back into the estate and may be taxed.
If death occurs within three years of the gift, the full rate of 40% applies (above the nil rate band). For deaths occurring between years three and seven, tapered relief reduces the effective IHT rate:
| Years between gift and death | IHT taper |
|---|---|
| 0–3 years | 0% reduction (full 40% rate applies) |
| 3–4 years | 20% reduction |
| 4–5 years | 40% reduction |
| 5–6 years | 60% reduction |
| 6–7 years | 80% reduction |
| 7+ years | 100% reduction (no IHT) |
Note: the taper applies to the tax charge, not the value of the gift. Also, the nil rate band is applied to the gift first (gifts use NRB before the estate), and taper only applies where the total PETs in the seven years before death exceed the nil rate band.
Regular Gifts from Income: The Most Powerful Exemption
The most underused IHT exemption — and potentially the most powerful for high earners — is the exemption for regular gifts from surplus income.
Gifts qualify for this exemption if:
- They are genuinely regular — an established pattern of giving, not occasional.
- They are made from surplus income — not from capital, and not reducing the donor's standard of living.
- They do not diminish the donor's normal standard of living — after the gift, the donor retains sufficient income to live normally.
If all three conditions are met, the gifts are immediately exempt from IHT — there is no £3,000 cap, no seven-year waiting period, and no limit on the total amount.
For a high earner with income significantly exceeding their expenditure, this can allow tens or even hundreds of thousands of pounds to leave the estate each year free of IHT.
The critical condition is documentation. HMRC requires evidence that gifts were regular, patterned, and from income. This means maintaining records:
- A simple spreadsheet showing annual income, expenditure, and the surplus available.
- Evidence of the pattern of gifts (bank statements, dated letters, standing order records).
- An HMRC form IHT403 is completed by the executors on death to claim this exemption — without records, it will not be accepted.
A practical approach is to calculate your annual surplus income each April, decide how much of it to gift, and establish a standing order or regular transfer to children or grandchildren. Do this for several years and you have an established, documented pattern.
Combining Exemptions
The IHT exemptions can be stacked:
- Annual exemption: £3,000 per year per donor.
- Small gifts: unlimited at £250 per recipient.
- Wedding gifts: up to £5,000 on occasion.
- Regular gifts from income: unlimited if criteria are met.
A high-net-worth couple with significant surplus income might legitimately gift:
- £6,000 per year under the annual exemption (£3,000 each).
- £500 per year under small gifts to each of, say, five grandchildren (£2,500 total).
- £60,000 per year as documented regular income gifts.
That is over £68,000 per year leaving the estate free of IHT without any seven-year clock running.
Gifting and the New Pension IHT Rules from April 2027
From April 2027, unspent pension funds will be brought into the scope of IHT (currently they are not). This changes the calculus significantly for many high-net-worth individuals who have been using pension accumulation as an IHT planning tool.
Under the new rules, estates with large pension pots will face a combined IHT charge on both the pension and the estate. This increases the urgency of:
- Drawing on pension income more aggressively to reduce the pension pot.
- Directing pension income into gifting programmes before it re-accumulates in the estate.
- Reviewing whether Beneficiary Drawdown Trusts and other death benefit nominations remain optimal.
The pension IHT reform makes the interaction between pension decumulation strategy and estate planning more important than ever. Those who were relying solely on pension accumulation as an IHT planning tool should review their position before April 2027.
Using Trusts Alongside Gifting
Gifts into a discretionary trust are immediately chargeable to IHT if they exceed the available nil rate band (they do not benefit from the PET regime). However, for families who want to remove assets from the estate while retaining some element of control over how those assets are eventually distributed, a combination of gift exemptions (feeding into a trust each year) can work effectively.
Alternatively, a Discounted Gift Trust (DGT) allows the settlor to make a gift into trust while retaining the right to regular income payments from the trust — a portion of the gift is immediately outside the estate (the "discount"), and the remainder follows the seven-year PET rules.
Practical Steps
- Quantify your estate. Understand what IHT your estate would face today and in 10–20 years at current growth rates.
- Assess your surplus income. How much do you earn above your spending requirements? This determines your gifting capacity under the income exemption.
- Establish a gifting programme. Set up regular standing orders; document income, expenditure, and gifts each year.
- Use the annual exemption without fail. £3,000 per donor per year is free money — use it.
- Consider the seven-year clock. Large gifts should be made early — the sooner the clock starts, the more time there is for the gift to become fully exempt.
How Global Investments Can Help
IHT planning is one of the most important — and most procrastinated — areas of financial planning for high-net-worth individuals. Global Investments works with clients to quantify their IHT exposure, design a systematic gifting strategy that fits within their lifestyle, and integrate gifting decisions with wider estate planning, trust structures, and charitable giving.
We take a practical, holistic view that connects IHT strategy to investment planning, pension drawdown, and the post-2027 pension landscape. An early start makes an enormous difference to the eventual outcome.
Tax rules are subject to change. IHT legislation is complex and this article provides a summary overview only. This article is for informational purposes and does not constitute personalised tax advice. Always seek qualified professional advice.
This article is for general information only and does not constitute financial, legal or tax advice. Rules, prices and regulations change; verify current requirements with a qualified adviser before acting.