What changes on 6 April 2027
Finance Act 2026, which received Royal Assent on 18 March 2026, amends the Inheritance Tax Act 1984 so that for deaths on or after 6 April 2027 most unused pension funds and pension death benefits are treated as an asset of the estate. HMRC's technical note, last updated on 29 May 2026, confirms the mechanics: the fund is valued at death and taxed alongside everything else, with the ordinary £325,000 nil-rate band stretched across the whole estate. Some benefits are excluded, chiefly dependants' scheme pensions from defined benefit schemes, death in service benefits, continuing joint life annuities and certain trivial commutation lump sums. Our guide to UK pensions and inheritance tax when you live abroad covers the detail.
Why leaving the UK does not help
Under the residence-based rules in force since 6 April 2025, once you stop being a long-term UK resident only your UK assets stay in scope. Many expats read that as a ten-year escape plan, and for foreign assets it broadly is. The pension is the exception: HMRC's technical note is explicit that inheritance tax still arises on unused funds in any scheme established in the UK, and a SIPP, UK personal pension or UK occupational scheme is established in the UK wherever you live. There is a second trap for couples abroad: the spouse exemption is only unlimited where the survivor is a long-term UK resident, otherwise it is capped at a cumulative £325,000, and a pension pot on its own can exhaust both that cap and the nil-rate band.
The double hit and your options
If you die at or after 75, beneficiaries also pay income tax at their marginal rate on what they draw, and from April 2027 the two charges stack: a pound of chargeable pension can become roughly 33 pence in the hands of an additional rate beneficiary, a combined rate of about 67%. The realistic options before April 2027 include faster drawdown (many treaties give your country of residence sole taxing rights over UK pension income), lifetime gifting under the 7-year rule, life cover written in trust to fund the bill, and for some a transfer to a QROPS, though the 25% overseas transfer charge must be navigated first. The right sequence is a modelling exercise, not a rule of thumb, and Horizon runs exactly this review for expats on fixed fees agreed upfront: book a free clarity call at /book.
