TRW & Co · Tax, Private Wealth & Family
Private Client Solicitors in London
Private client solicitors London families and entrepreneurs instruct help them hold, protect and pass on wealth. With residence-based inheritance tax since April 2025, business property relief capped at £2.5 million from April 2026 and pensions entering the estate from April 2027, many existing wills, trusts and succession plans now need to be reviewed.
Key pointSomeone who has been UK tax resident for 10 of the last 20 years is now within inheritance tax on worldwide assets, and that exposure can continue for up to 10 years after leaving the UK.
At a glance
Bands frozen to 2031
The £325,000 nil-rate band and £175,000 residence nil-rate band are frozen until April 2031, pulling more estates into inheritance tax.
£2.5m relief allowance
From 6 April 2026, 100% business and agricultural property relief applies to the first £2.5 million of qualifying property, 50% above.
Pensions in the estate
For deaths on or after 6 April 2027, most unused pension funds and death benefits count towards the estate for inheritance tax.
Residence replaces domicile
Since 6 April 2025, long-term UK residents, resident for 10 of the last 20 years, are taxed on worldwide assets.
Seven-year gift rule
Gifts to individuals escape inheritance tax if the donor survives seven years, with taper relief for deaths between three and seven years.
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What private client solicitors London families instruct actually do
Private client solicitors London families, entrepreneurs and internationally mobile individuals instruct advise on how wealth is held, protected, passed on and taxed. The work spans wills and succession, trusts, lifetime gifts, inheritance tax and capital gains tax planning, residence for tax purposes, lasting powers of attorney, the administration of estates and the governance of family businesses and investment vehicles.
Private client law has changed more in the last two years than in the previous twenty. The domicile-based system for non-UK income and inheritance tax was replaced by residence-based rules from 6 April 2025. Business and agricultural property relief were reformed from 6 April 2026. And from 6 April 2027, most unused pension funds will fall into the estate for inheritance tax. Plans drawn up under the old rules may no longer do what families expect.
The legal question usually arises at a life event: selling a business, moving to or from the UK, marriage or divorce, the birth of grandchildren, a parent's declining capacity, or a death. The best private client solicitors London clients rely on plan well before those moments, so that the family has choices rather than deadlines.
The legal and tax framework for private wealth
Inheritance tax is governed by the Inheritance Tax Act 1984, as amended by successive Finance Acts, most recently the Finance Act 2026. Capital gains tax and income tax on investment income sit in separate statutes. Trusts are governed by general equity and by statutes such as the Trustee Acts, and trustees of most UK express trusts, and many non-UK trusts with UK connections, must register on HMRC's Trust Registration Service.
Succession law in England and Wales is founded on testamentary freedom: a person can leave their estate to anyone, subject to formal rules for making a valid will and to claims by family members and dependants under the Inheritance (Provision for Family and Dependants) Act 1975. Where there is no valid will, the intestacy rules in the Administration of Estates Act 1925 decide who inherits. Decisions for people who lack capacity are governed by the Mental Capacity Act 2005, with lasting powers of attorney registered by the Office of the Public Guardian and disputes heard by the Court of Protection.
Scotland and Northern Ireland differ. Scots law gives spouses, civil partners and children fixed "legal rights" in movable property that a will cannot remove, and Scotland has its own rules on wills, trusts and powers of attorney. Northern Ireland has separate succession legislation, although inheritance tax applies across the UK.
Inheritance tax in 2026: the numbers private client solicitors London advise on
The figures below shape most planning conversations in 2026. They are drawn from HMRC's inheritance tax guidance and policy papers, and should be checked again before any decision is implemented.
| Rule | Current position | Planning point |
|---|---|---|
| Nil-rate band | £325,000, frozen until April 2031 | Unused band can transfer to a surviving spouse or civil partner |
| Residence nil-rate band | Up to £175,000 where a home passes to direct descendants; tapered for estates over £2 million | Will drafting and lifetime gifts can preserve or lose it |
| Main rate | 40% above available bands; 36% on some assets if 10% or more of the net estate is left to charity | Charitable legacies can reduce the rate on the rest of the estate |
| Lifetime gifts | Gifts to individuals are free of tax if the donor survives seven years; taper relief reduces tax on gifts made three to seven years before death | Start early, keep records, and avoid reserving a benefit |
| Business and agricultural property relief | From 6 April 2026, 100% relief on the first £2.5 million of combined qualifying property, 50% above; unused allowance transferable between spouses | Family company shareholders need refreshed wills and shareholder agreements |
| Unquoted-market shares (such as AIM) | Relief reduced to 50% from 6 April 2026 | Portfolio strategies built around 100% relief need review |
| Pensions | Most unused pension funds and death benefits included in the estate for deaths on or after 6 April 2027 | Pension-led estate plans need rebalancing |
| Payment deadline | Inheritance tax is due by the end of the sixth month after death | Plan liquidity so executors are not forced to sell |
HMRC's papers on agricultural and business property relief and unused pension funds explain the reforms. Our articles on business property relief reform and pensions and inheritance tax go further.
Residence, not domicile: the new rules for internationally mobile families
From 6 April 2025 the domicile and deemed domicile rules were replaced. Under HMRC's long-term residence guidance, a person is a long-term UK resident in a tax year if they were UK tax resident for the previous 10 consecutive years, or for at least 10 of the previous 20 years. Long-term residents are within inheritance tax on their worldwide assets.
Long-term residence can continue for up to 10 tax years after leaving the UK, with a shorter "tail" for those resident for fewer years: three years after departure for someone resident for 10 to 13 years, rising by one year for each additional year of residence. Trust assets are now generally taxed by reference to the settlor's long-term residence status, subject to transitional protection for some trusts.
For income tax and capital gains tax, the remittance basis has been replaced by a four-year foreign income and gains regime. It is available only to individuals in their first four years of UK tax residence after at least 10 consecutive years of non-residence. Our guide to the non-dom and FIG regime and our article on the statutory residence test explain how residence is determined day by day.
Key decisions and how private client solicitors London advise on them
Gift now, or keep control
Outright lifetime gifts start the seven-year clock and remove growth from the estate, but the donor loses control and the gift may be exposed to the recipient's divorce or insolvency. A gift of an asset that the donor continues to use, such as a home, is usually a gift with reservation and stays in the estate. Gifts of shares or property may also trigger capital gains tax. The answer often combines annual exemptions, regular gifts out of surplus income and larger gifts into a structure.
Trusts
Discretionary trusts give trustees flexibility and protect assets for young or vulnerable beneficiaries, but most lifetime transfers into them are immediately chargeable to inheritance tax above the nil-rate band, and the trust then faces periodic and exit charges. Trusts still have an important role in protection, control and succession planning, especially when combined with business property within the new allowance. Our trusts team advises trustees and settlors.
Family investment companies
A family investment company lets parents keep control through voting shares and articles while passing value to the next generation through other share classes. Income is taxed at corporation tax rates, but extracting value is taxed again. They suit long-term investors more than those needing regular income. See our article on family investment companies.
Protecting against loss of capacity
Lasting powers of attorney for property and financial affairs, and for health and welfare, let trusted people act if capacity is lost. Without them, the family may need to apply to the Court of Protection for a deputy, which is slower and more expensive. Business owners should also consider a separate attorney for business assets. Our powers of attorney team handles both routes.
If your estate plan relies on business property relief, pension wealth or non-UK assets being outside inheritance tax, it was probably designed for rules that no longer apply. A short review of wills, shareholder agreements, trust deeds and pension nominations against the 2025–27 changes is usually the highest-value step a family can take this year.
How a private client review runs
A structured review is the most efficient way to bring an existing plan up to date. It usually takes a few meetings and works best when your accountant and financial adviser are involved from the start.
- Family and asset map. We record family relationships, residence history, and every material asset, including where it is located, how it is owned and what documents govern it.
- Objectives. We discuss what the family wants: provision for a spouse, fairness between children, protecting a business, philanthropy, or keeping control.
- Tax and legal analysis. We identify inheritance tax exposure, capital gains tax on proposed transfers, the effect of residence rules and any foreign succession or forced heirship law.
- Options and recommendations. We set out realistic options with their tax effect, cost and practical burden, coordinating with accountants and investment advisers.
- Documents. We prepare wills, trust deeds, lasting powers of attorney, letters of wishes and, where relevant, shareholder agreement amendments or family company articles.
- Execution and registration. We supervise signing and witnessing, register lasting powers of attorney and trusts as required, and file any HMRC returns.
- Periodic review. We diarise reviews after Budgets, life events, residence changes and business transactions.
Documents to assemble
- Existing wills, codicils, letters of wishes and any foreign wills.
- A residence history listing the countries where you have been tax resident in each of the last 20 years.
- Title documents for property in the UK and abroad, including Bangladeshi deeds and mutation records.
- Company constitutions and shareholder agreements for any family or trading business.
- Trust deeds, deeds of appointment and Trust Registration Service records.
- Pension statements and expression-of-wish nominations.
- Records of lifetime gifts made in the last seven years, with dates and values.
- Marriage, civil partnership and divorce documents, and any nuptial agreements.
- Existing lasting powers of attorney or foreign powers of attorney.
Risks and common mistakes
Relying on an out-of-date will
Wills written before April 2026 may leave business property to a spouse in a way that wastes the new £2.5 million allowance, or pass a home in a way that loses the residence nil-rate band. Marriage generally revokes an earlier will in England and Wales, and divorce changes how gifts to a former spouse take effect. A will that refers to a business, trust or pension arrangement that has since changed may simply not work as intended. Review every will after a Budget that affects reliefs and after any significant life event.
Assuming non-UK assets are outside inheritance tax
Under the long-term residence rules, someone UK resident for at least 10 of the last 20 years is within inheritance tax on worldwide assets, regardless of where they consider home. Many families of overseas origin, including British Bangladeshi families, are now within scope on property in Bangladesh or elsewhere. The tail period means that leaving the UK does not end exposure immediately. Mapping residence history year by year is the starting point for any planning.
Gifts with strings attached
Giving away a property but continuing to live in it rent-free, or giving shares but continuing to receive the dividends, usually counts as a gift with reservation of benefit. The asset stays in the estate for inheritance tax, while the gift may still trigger capital gains tax. There are narrow exceptions, such as paying full market rent or sharing occupation with the recipient. Records showing what was given, when and on what terms are essential for executors years later.
Failing to register a trust
Most UK express trusts must register on the Trust Registration Service, whether or not they pay tax, and some non-UK trusts with UK connections must register too. Trustees must keep the register up to date. Families often discover unregistered trusts created by a parent's will or a life insurance policy written in trust. Late registration can lead to penalties and complicates transactions such as property sales, where banks and conveyancers increasingly check the register. Our article on the Trust Registration Service explains the rules.
No plan for liquidity on death
Inheritance tax is due by the end of the sixth month after death, and interest runs on late payment. Estates rich in property or private company shares but light on cash can be forced into rushed sales. Instalment options exist for some assets, and life insurance written in trust can fund the liability outside the estate. With pension funds coming into scope from April 2027, personal representatives will also need to coordinate with pension administrators, so the plan should identify where cash will come from.
The rules changed under most families' feet between 2025 and 2027. The plan that was right three years ago may now be the most expensive option on the table.
Cross-border wealth: Bangladesh, the EU, the Gulf and Asia
International families face two questions in every country: which succession law applies, and which tax applies. The answers rarely match.
Bangladesh
Succession in Bangladesh is largely governed by personal law tied to religion, so a Muslim's estate typically passes under Islamic inheritance rules, with fixed shares that a will can vary only within limits. Land in Bangladesh is generally governed by Bangladeshi law wherever the owner lives. A UK will may therefore be ineffective for Bangladeshi land, while that land may still count for UK inheritance tax if the owner is a long-term UK resident.
Practical problems follow: title records that still show a deceased grandparent, co-owned family land that cannot be sold without every heir's consent, and powers of attorney that must be executed and authenticated in a form Bangladeshi authorities accept. Private client solicitors London families of Bangladeshi heritage instruct should look at both systems together. We often recommend separate, coordinated wills and work with TRW & Co colleagues in Dhaka, Chattogram and Sylhet on title, mutation and transfer. See our UK–Bangladesh succession team and our article on a UK will with Bangladesh assets.
The EU, the Gulf, Singapore and China
Many EU states apply the EU Succession Regulation, which the UK did not adopt; a UK national with assets in an EU country may be able to choose the law of their nationality to govern succession there. In the UAE, non-Muslims can make wills through specific registries, and the default rules may otherwise apply. Singapore and China each have their own probate and recognition processes. Our international private client team coordinates with TRW & Co's offices in Singapore, Dubai, China, Italy and Switzerland.
How TRW & Co's private client solicitors London team helps
Our London office is authorised and regulated by the Solicitors Regulation Authority. We advise individuals, families, trustees and family businesses.
Estate and succession planning
We prepare wills, trusts and letters of wishes that reflect the 2026 relief reforms, residence rules and family objectives, and coordinate foreign wills where assets are abroad.
Inheritance tax planning
We advise on lifetime gifts, trusts, business property relief, pension changes and liquidity, working with accountants and financial advisers on the numbers.
International families
We advise on long-term residence, the four-year FIG regime, arrival and departure planning, and cross-border succession conflicts.
Family business succession
We review shareholder agreements, articles and family company structures so that ownership, control and relief work together on death or retirement.
Capacity and protection
We prepare lasting powers of attorney and act in Court of Protection deputyship applications, protecting older and vulnerable clients.
Estates and disputes
We administer estates, handle probate and inheritance tax returns, and advise on contested estates. Where advocacy in the higher courts is required, we instruct specialist counsel.
See also our wills and estate planning and probate pages, our article on inheritance tax planning, and the full list of our practices.
Checklist for decision-makers
- When were your wills last reviewed, and do they reflect the April 2026 business property relief rules?
- How many of the last 20 years have you, and your spouse, been UK tax resident?
- Does your estate plan assume pensions are outside inheritance tax after April 2027?
- Are all family trusts registered and their records up to date?
- Do you have lasting powers of attorney, including one that covers business assets?
- Do you hold property abroad, and is there a local will or succession plan for it?
- Have lifetime gifts been recorded with dates and values?
- Where will cash come from to pay inheritance tax within six months of death?
To arrange a review with our private client solicitors London team, contact us at info@trw.co or on +880 1779 127165, or visit us at Holborn Gate, 330 High Holborn, London WC1V 7QH.
Frequently asked questions
01What does a private client solicitor do?
A private client solicitor advises individuals and families on their personal legal and tax affairs: wills and succession, trusts, lifetime gifts, inheritance tax and capital gains tax planning, tax residence, lasting powers of attorney, Court of Protection matters and estate administration. For business owners the work extends to shareholder agreements and family company structures. The aim is to protect wealth, provide for the family and reduce avoidable tax, within the law and in a way the family can sustain.
02How have the 2026 business property relief changes affected family businesses?
From 6 April 2026, 100% relief applies only to the first £2.5 million of combined qualifying business and agricultural property, with 50% relief above that. Any unused allowance can be transferred to a surviving spouse or civil partner. Shares traded on markets such as AIM now qualify for 50% relief. Owners should review wills, shareholder agreements, life insurance and lifetime gifting to use allowances efficiently and to make sure there is cash to pay any tax due.
03Am I a long-term UK resident for inheritance tax?
Under the rules in force since 6 April 2025, you are a long-term UK resident in a tax year if you were UK tax resident for the previous 10 consecutive years or for at least 10 of the previous 20 years. Long-term residents are within inheritance tax on worldwide assets. The status can continue for up to 10 tax years after leaving, with shorter periods for those resident for fewer years. Residence is decided under the statutory residence test.
04Will my pension be subject to inheritance tax?
For deaths on or after 6 April 2027, most unused pension funds and pension death benefits will be included in the value of the estate for inheritance tax. Personal representatives will be responsible for reporting and paying the tax. Death in service benefits payable from a registered pension scheme will remain outside the charge. People who planned to leave pension wealth untouched as a tax-efficient inheritance should revisit their plans and nominations.
05Do I need to register my family trust?
Most UK express trusts must be registered on HMRC's Trust Registration Service, even if they have no tax to pay, and some non-UK trusts with UK connections must register too. Trustees are responsible for registration and for keeping details up to date. Trusts created by a will or by a life policy written in trust are commonly overlooked. Late registration can result in penalties and can delay transactions.
06Does my UK will cover property in Bangladesh?
Not reliably. Land in Bangladesh is generally governed by Bangladeshi law, and succession there often follows personal law tied to religion, which may limit what a will can do. A UK will may not be effective for Bangladeshi land, but if you are a long-term UK resident that land can still be within UK inheritance tax. Coordinated wills in each jurisdiction, prepared with local lawyers, usually work best.
07How can TRW & Co help?
Our London office, regulated by the Solicitors Regulation Authority, advises on wills, trusts, inheritance tax planning, residence, family business succession, lasting powers of attorney, the Court of Protection, estate administration and contested estates. With TRW & Co offices in Bangladesh, Singapore, Dubai and elsewhere, we coordinate cross-border plans. Contact us at info@trw.co to arrange a review.
Sources and official materials
- Inheritance Tax — Thresholds, rates, gifts and the seven-year rule
- Inheritance Tax if you're a long-term UK resident — Residence-based rules from 6 April 2025
- Changes to agricultural property relief and business property relief — The £2.5 million allowance from 6 April 2026
- Inheritance Tax: unused pension funds and death benefits — Pensions in the estate from 6 April 2027
- Check if you can claim the 4-year foreign income and gains regime — Replacement for the remittance basis
- Register a trust as a trustee — Trust Registration Service
- Mental Capacity Act 2005 — Lasting powers of attorney and the Court of Protection
- Inheritance Tax Act 1984 — The inheritance tax statute
General information only, current as at 21 October 2026. It is not legal advice and does not create a solicitor–client relationship. It reflects the law of England and Wales unless stated otherwise; Scotland and Northern Ireland have separate legal systems, and the law changes frequently. Check current official sources and take advice on the facts of your matter.