How will pensions being counted for Inheritance Tax change your plan?
Unused pension funds are due to be brought within the Inheritance Tax net from April 2027. That change removes the single rule on which most UK retirement withdrawal advice was built, and for estates above the nil-rate bands it inverts the order in which accounts should be spent.
- What changes: unused pension funds count toward the estate for Inheritance Tax from April 2027.
- Who it affects: estates above the available nil-rate bands, which is a minority of households.
- The double charge: for a non-spouse beneficiary, 40% on the fund and Income Tax when they draw it.
- The response: use the personal allowance and basic-rate band on pension income every year rather than deferring.
Tom's plan, like almost every plan written in the last decade, left the SIPP untouched for as long as possible. That was correct advice under the rules it was written for, and it stops being correct for him in April 2027.
01 What the old rule did
Money still inside a pension on death sat outside the estate for Inheritance Tax, and where death occurred before 75 it could pass to beneficiaries free of Income Tax as well. That combination made an untouched pension the most efficient asset to die holding, and it drove the whole ordering of UK withdrawal advice.
The consequence was households living off ISAs and general investment accounts while a pension compounded untouched. The Institute for Fiscal Studies documented the behaviour and identified the exemption as the cause, which is part of why it was reformed.
None of that advice was wrong. It was correct for the rules in force, and it is the rules that are changing.
Source: Death and taxes and pensions
02 What replaces it
From April 2027, unused pension funds are due to be counted as part of the estate. For a spouse or civil partner nothing changes in practice, because transfers between them remain exempt without limit. For any other beneficiary the fund becomes chargeable at 40% above the available bands.
The Income Tax treatment on the beneficiary's side is unchanged, which is where the arithmetic gets hard. A non-spouse beneficiary of a fund from someone who died at or after 75 pays Income Tax at their marginal rate on withdrawals, and the fund may already have borne Inheritance Tax.
That is the case for drawing the pension down during life rather than preserving it, and it applies specifically to estates above the bands.
Shows: the Inheritance Tax on an estate before and after unused pension funds are counted. Ignores: Income Tax paid by the beneficiary, the residence band taper, gifts, and any change to the announced rules.
On the defaults above, the worked example shows £40,000. Counting the pension adds £40,000 of Inheritance Tax, before any Income Tax the beneficiary pays on withdrawals.
Source: Inheritance Tax
03 Who actually needs to act
A minority. Roughly one estate in twenty pays Inheritance Tax, and the bands available to a married couple with a home passing to children reach £1 million. Below that, the change has no effect and there is no reason to alter a withdrawal plan for it.
Where it does bite, the response is not dramatic. It is to use the annual allowances that were being left unused: draw pension income up to the personal allowance and, where the plan supports it, the basic-rate band, every year. That was worth doing anyway and is now worth more.
The instinct to empty a pension quickly is usually wrong. Withdrawing large amounts in a single year pushes income into the higher and additional rates, and 40% Income Tax now to avoid 40% Inheritance Tax later is not a saving.
The arithmetic that makes early drawing worthwhile is narrow, and it is worth stating rather than assuming. Money drawn at the basic rate costs 20% now against a possible 40% later, which is a clear gain. Money drawn at the higher rate costs 40% now against 40% later plus the beneficiary's own Income Tax, which is a smaller gain and only exists for a non-spouse beneficiary. Money drawn at the additional rate is usually worse than leaving it. So the band you are drawing into decides the answer, not the size of the estate.
04 The interactions to check
Drawing more pension income raises your taxable income, which can affect the personal allowance taper, the High Income Child Benefit Charge and means-tested benefits. It also triggers the money purchase annual allowance if you are still contributing, which caps future contributions at £10,000.
Moving pension money into an ISA does not remove it from the estate — an ISA is fully chargeable — so the transfer buys tax-free growth rather than an Inheritance Tax saving. Gifting the withdrawn money does remove it, subject to the seven-year rule or the immediate exemptions.
And the expression of wish still matters. Beneficiary drawdown remains available, and who receives the fund and how they take it affects the Income Tax side even after the Inheritance Tax position changes.
05 What to do before April 2027
Work out whether your estate, including pensions, exceeds the bands available to you. If it does not, do nothing. If it does, start using the personal allowance and basic-rate band on pension withdrawals now rather than at 75, and consider whether surplus income can fund regular exempt gifts.
Review the will and the expression of wish together, because the two interact and the second is usually decades out of date. And treat announced legislation as announced rather than enacted — the detail can move, and a plan that only works under one specific version of the rules is fragile by construction.
The durable version of the advice does not depend on the change at all: use every annual allowance you are given, because none of them carries forward.
One further thing is worth doing now and costs nothing: write down what the estate actually contains, pensions included, with a current value against each line. Most households discover on doing it that they are either comfortably below the bands or clearly above them, and that answer settles the whole question in an afternoon.
Source: Plan your retirement income
I changed my own advice when this was announced, and I would rather say so than pretend the old answer was always wrong. It was right for the rules it was written under. What it never justified was leaving the personal allowance unused for nine years while living off an ISA, and that was a mistake even when pensions were exempt. So the practical instruction is the same one it should always have been: draw enough pension each year to use your allowance, and stop trying to die with a pension intact. For most households the estate was never in the charge anyway, and nothing here requires them to do anything at all.
FAQ
Does this affect my spouse inheriting my pension?
No. Transfers between spouses and civil partners remain exempt from Inheritance Tax without limit, so a pension passing to a surviving spouse is unaffected by the change.
Should I empty my pension before April 2027?
Almost certainly not. Large withdrawals push income into the higher and additional rates, and paying 40% Income Tax now to avoid 40% Inheritance Tax later saves nothing. Using the personal allowance and basic-rate band each year is the measured response.
Does moving money into an ISA help?
Not for Inheritance Tax. An ISA is fully within the estate, so the transfer buys tax-free growth rather than an exemption. Gifting the money away does remove it, subject to the seven-year rule or the immediate exemptions.
What if my estate is below the nil-rate bands?
Then the change does not affect you. Roughly one estate in twenty pays Inheritance Tax, and a married couple with a home passing to children can have £1 million of bands available. Below that, no change to your withdrawal plan is warranted.
Sources
Regulator references
- Inheritance Tax · GOV.UK · 2025The nil-rate band, the 40% rate and what forms part of the estate.Last verified: 2026-09-07
- Income Tax rates and Personal Allowances · GOV.UK · 2025The band boundaries every figure in this post is calculated against.Last verified: 2026-09-07
- Tax on your private pension contributions · GOV.UK · 2025The relief, allowance and charge framework the whole post sits inside.Last verified: 2026-09-07
- Plan your retirement income · GOV.UK · 2025The government's own sequence for turning pension pots into income.Last verified: 2026-09-07
Research
- Death and taxes and pensions · Institute for Fiscal Studies · 2022Quantifies the estate-planning advantage of leaving a pension untouched, and the behaviour it produces.Last verified: 2026-09-07
Calculator unit tests · the assertions this page's worked example is checked against, and their last result
Changelog
- 2026-09-07 — initial publish (new format)
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