Inheritance Tax 2026 Conference

Introduction

Chaired by Georgia Bedworth of Ten Old Square, this year’s Inheritance Tax Conference brings together a panel of leading experts to examine the most pressing developments reshaping the IHT landscape. With major reforms coming into force in 2025 and 2026, practitioners are facing a period of unprecedented change affecting reliefs, valuations, international clients, pensions and the Court of Protection. This conference offers timely, practical insight into these shifts, helping advisers navigate new complexities, anticipate risk areas and support clients in adapting their estate planning with confidence.

Conference Agenda

This conference will cover the following:

9.30am - 10.15 am: The Changes to Agricultural and Business Property Relief and Estate Planning

Georgia Bedworth, Ten Old Square

This session will explore the changes to Agricultural and Business Property relief announced in the 2024 Budget and implemented on 6 April 2026. The implications of the changes will be considered along with practical steps that clients might take in light of the changes. Topics covered will include discussion of the changes, estate planning including whether to top up qualifying pre-commencement settlements and tax efficient will drafting.

Learning Outcomes

• A thorough understanding of the APR and BPR changes and what they mean for clients
• How best to assist clients to plan their estates in light of the changes
• How to deal with the changes when drafting wills

10.15am - 11.00am: Inheritance Tax for International Clients

Oliver Marre, Barrister, 5 Stone Buildings

This session will help you understand the post April 2025 IHT regime and the IHT taxation of trusts settled by non-residents together with IHT issues generally for internationally mobile clients, covering the following:

• IHT for new UK residents
• IHT for departing former residents
• Pre-arrival planning and trusts

Morning break for refreshments

11.15am - 12.00pm: Key Valuation Principles for Inheritance Tax

Sarah Wray, Partner, Charles Russell Speechlys LLP

The session will explore some of the valuation idiosyncrasies within the inheritance tax legislation and the opportunities this can provide for tax planning. The session will cover special valuation principles such as shareholder discounts, “package” valuations, related property valuations and the importance of valuation in the context of reliefs. It will also consider practical case studies of where an individual has multiple interests in an asset - such as through direct and trust structures - and how they are valued.

The learning outcomes will be:

• To understand the special valuation rules which can apply to certain assets, reliefs and ownership structures
• To explore planning opportunities which arise from valuation principles

12.00pm - 12.45pm: Inheritance Tax Mitigation for Clients Who Lack Capacity

Ruth Hughes KC, 5 Stone Buildings

This aim of this session is to help you to feel confident advising when an application to Court to authorise inheritance tax driven gifting is appropriate and will cover the following:

• How the applications to the Court of Protection work
• Common ways in which inheritance tax is mitigated in the Court of Protection
• Showing historic wishes to gift/save tax
• Affordability

12.45 - 1.00pm: Questions

Lunch Break

2.00pm - 2.50pm: The New IHT Regime for Pensions: UK and Offshore Schemes Under the 2026 Rules

James Quarmby, Partner, Stephenson Harwood LLP

This session provides a detailed examination of the new inheritance tax regime for pension death benefits taking effect from April 2026. It will explain how the reforms apply to UK registered pension schemes, SIPPs, defined benefit arrangements and offshore structures such as QROPS and employer superannuation funds.

The session will explore the interaction between the new rules and existing IHT provisions, including the settlements regime, gifts with reservation, POAT and the spouse exemption. It will highlight the key risk areas for clients with significant pension wealth, cross‑border arrangements or complex beneficiary structures, and will outline practical planning strategies to mitigate exposure.

Real‑world case studies will illustrate how the rules apply to UK‑domiciled and internationally mobile individuals, and how advisers can help clients restructure their pension and estate planning in light of the 2026 changes.

By the end of this session, delegates will be able to:

• Understand the scope and operation of the new IHT charge on UK and offshore pension death benefits
• Identify the key risk areas, including GWR, POAT, settlements interactions and ‘death proximate’ transfers
• Advise clients on practical planning strategies for UK and non UK pensions under the post 2026 regime

2.50pm - 3.40pm IHT Planning and the Court of Protection

Georgia Bedworth, Ten Old Square

This session will examine how inheritance tax planning can be undertaken for individuals who lack capacity and the role of the Court of Protection in authorising such arrangements. It will explore the legal framework governing statutory wills and lifetime gifting applications, the evidential requirements for demonstrating best interests and the practical challenges that arise when balancing tax efficiency with the protected party’s welfare.

The session will also consider common planning scenarios, the approach taken by the Court to IHT motivated gifts and how advisers can prepare robust applications supported by clear financial analysis and evidence of historic wishes. Recent case law and emerging trends will be discussed to help practitioners anticipate how the Court is likely to respond to future applications.

Learning Outcomes

• Understand when and how the Court of Protection may authorise IHT motivated gifts or statutory will changes for clients who lack capacity
• Identify the key evidential and practical requirements for preparing successful applications, including demonstrating best interests and affordability
• Advise on appropriate IHT planning strategies for clients lacking capacity and recognise the limits of what the Court is likely to approve

PM break

4pm - 4.45pm - Close: Questions

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.