This table summarises the time limits within which taxpayers, including personal representatives (PRs) and trustees, must file inheritance tax (IHT) returns, update HMRC with corrected or new information and pay any tax due, as well as other IHT compliance deadlines. For information on IHT compliance in relation to estates and trusts, see Practice Notes: Estates—IHT returns and tax compliance and Trusts—IHT returns and tax compliance. Table—by category of action Action Time limit Reference Payment of IHT Pay IHT on deceased’s estate or IHT otherwise arising as a result of deceased’s death • six months from the end of the month in which the deceased died, or • where the instalment option is available, first instalment is due six months from the end of the month in which the deceased died, with the remaining nine instalments plus interest paid annually (provided the instalment option remains available and the asset has not been disposed

A discretionary trust is a very flexible form of trust. In these trusts, the trustees have the discretion to determine when, how and to whom distributions of capital and income should be made. Beneficiaries (or a class of beneficiaries) are named in the trust deed and it is left entirely up to the trustees to decide which of the potential beneficiaries is to benefit, sometimes with the guidance of a letter of wishes. Why discretionary Will trusts are used For various reasons, it may not be desirable to leave assets directly to a beneficiary in the Will. For example: • the beneficiary is, or in the future might become, bankrupt • the beneficiary is, or in the future might be, going through a divorce • the beneficiary is disabled, needs help with managing money or receives state benefits where any money received directly from the estate might affect their entitlement to such benefits • the potential beneficiary is very young at the date of the making of the Will and it is not prudent to make

FORTHCOMING CHANGE relating to IHT on pension death benefits: At Autumn Budget 2024 on 30 October 2024, the government announced that it will bring unused pension funds and death benefits payable from a pension into a person’s estate for IHT purposes from 6 April 2027. New section 150A of the Inheritance Tax Act 1984 is added by section 66 of the Finance Act 2026, with effect from 6 April 2027 (IHTA 1984, s 71) and applies to defined contribution and defined benefit schemes, as well as to UK registered schemes and qualifying non-UK pension schemes. For more information, see Practice Note: Hot topic—the reform of inheritance tax on pensions and News Analyses: Autumn Budget 2024—Private Client analysis — Inheritance tax and HMRC confirms new IHT rules on unused pension funds to apply from 6 April 2027. The need to value the estate When an individual dies they are considered to have made a 'transfer of value' equal to the value of their estate immediately before death.

Woodlands may attract one of three different types of relief from inheritance tax (IHT) depending on the nature of the land and timber operations: • agricultural property relief (APR) Woodlands may obtain APR if they are occupied with agricultural land or pasture and their occupation is ancillary to that of the agricultural land or pasture, eg a strip of woodland acting as a wind shelter for farmland. For further detail about BPR, see Practice Note: IHT—agricultural property relief • business property relief (BPR) Woodlands may qualify for BPR if they are run as a commercial business (eg orchards or nurseries) or otherwise generate business profits by regularly producing timber. For further detail about BPR, see Practice Note: IHT—business property relief • woodlands relief Woodlands may also qualify for woodlands relief and this will generally be considered on a death if neither APR nor BPR is available APR and BPR are usually to be preferred to woodlands relief. This is because APR and BPR effectively provide the equivalent of an exemption

The Institute of International and European Affairs (IIEA) has published an analysis examining how President Trump's 'Liberation Day' tariffs, which set different rates for the UK and EU, affect Northern Ireland under the Windsor Framework. The analysis highlights that Northern Ireland faces potential exposure to dual tariff regimes when the current 90-day pause expires on 9 July 2025. While businesses in Northern Ireland could theoretically benefit from this position, the IIEA notes these advantages depend on the arrangements becoming permanent.

The Institute of International Finance (IIF), the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) have submitted a joint comment letter to the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on the proposed Basel III endgame capital rule for large banking organisations and firms with significant trading activity. The associations focused on provisions relating to the Fundamental Review of the Trading Book, credit valuation adjustment risk and counterparty credit risk, including securities financing transactions, derivatives and the standardised approach for counterparty credit risk. They supported the regulators’ efforts to improve the risk sensitivity of the capital framework but argued that further refinements are needed because capital calibration affects market liquidity, client hedging, financing services and the functioning of US capital markets. Their recommendations are aimed at enhancing risk sensitivity, improving consistency across capital rules and reducing unnecessary operational burdens, and they proposed that the final rule should not take effect before 1 January 2028.

The International Islamic Financial Market (IIFM) has published new templates for issuing Sukuk Al Mudarabah Tier 1. The aim of the new standardised documentation is to improve the clarity and transparency within the industry by establishing a recognised suite of documents for common clauses and agreements. Included in this are Declarations of Trust, Prospectuses and Master Mudarabah Agreements. It is hoped that the release of the standard documents will also improve cost efficiency by reducing the time it takes to draft Sukuk documentation.

The International Institute for Sustainable Development (IISD) has developed a model inter se agreement to neutralise the sunset clause in the Energy Charter Treaty (ECT) between the EU and non-EU contracting parties. This move aims to reduce investment disputes arising from energy transition policies, especially those related to fossil fuels. By preventing claims like the one filed by UK-based electricity distribution investors against Finland in August 2024, the inter se agreement can help mitigate the risks associated with legacy investments.

The International Law Compliance (ILC) has published the report on Compliance with Investment Treaty Arbitration Awards 2024 3rd edition. The report includes the latest data from the United Nations Conference on Trade and Development (UNCTAD) which reveals a significant increase in investor-state dispute settlement (ISDS) cases, with 1,332 known treaty-based arbitrations to date. Of the 958 concluded cases, 37.7% were decided in favour of respondent states. The report highlights Spain's position as the world leader in unpaid arbitration awards, with 24 outstanding, surpassing Venezuela and Russia. Spain also tops the list of Energy Charter Treaty disputes with 52 initiated cases.

The International Law Institute - South African Centre for Excellence (ILI-SACE), in collaboration with the International Centre for Settlement of Investment Disputes (ICSID), has announced a premium programme on Investment Arbitration. Scheduled for 2-10 December 2024, in Johannesburg, South Africa, the course aims to enhance participants' expertise in investment arbitration practices, with a particular focus on ICSID procedures. The faculty comprises distinguished experts, including ICSID's Deputy Secretary-General Gonzalo Flores and Legal Counsel Ella Josepha Rosenberg, alongside Dr Borzu Sabahi, a leading international arbitration lawyer. Upon completion, participants will receive a joint certificate from ILI-SACE and ICSID, underscoring the programme's significance in the field of international investment dispute resolution.

The International Labour Organization (ILO) has published guidance titled ‘International labour standards and migrant workers’ rights: Guide for policymakers and practitioners’, bringing together in a single resource the rights set out in ILO standards most relevant to migrant workers throughout the migration process. The Guide provides practical explanations, guidance from ILO supervisory bodies and examples from across regions and addresses cross-cutting issues such as social dialogue, gender equality, violence and harassment, fair recruitment, climate-induced mobility and access to justice.

The Immigration Law Practitioners’ Association (ILPA) Blog has published an update outlining the complex legal challenges facing Afghan nationals who served as interpreters alongside the British Armed Forces. Following legal proceedings over delayed evacuations under the Afghan Resettlement Programme, Minister Luke Pollard confirmed that in-country assistance for withdrawals from Afghanistan has now ended.