09/10/2026
For the accountants, advisers and solicitors following this page.
HMRC published a second technical note on the inheritance tax treatment of pensions in August, covering the mechanics rather than the principle: notional pension property, the information-sharing requirements between schemes and personal representatives, withholding notices, the pensions direct payment scheme, and clearance.
It is worth reading properly if you have clients with substantial defined contribution pots, because it is the first material that answers the practical question - not “is the pension in the estate” but “who tells whom, in what order, and by when”.
Three implications we are already working through with firms:
1. Executor briefing becomes part of the planning conversation, not an afterthought. Your client’s named executor is about to acquire a reporting duty nobody has explained to them.
2. Liquidity planning gets earlier. The tax falls due before probate, on an asset the estate cannot access without the scheme’s cooperation.
3. Expression of wish forms need reviewing against the will, not in isolation. We are finding plenty that contradict each other.
HMRC has said further secondary legislation and guidance will follow ahead of April 2027, so this is not the final word.
Happy to discuss a case in confidence. Link to the technical note in the comments.
General information only - not advice on your circumstances.