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Flexible Reversionary Trust

The FRTs (Flexible Reversionary Trust) are effective for IHT planning purposes and are versatile in meeting the client’s income needs.


  • Save 40% IHT after 7y
  • Money is invested
  • Optional access capital each year
  • Keep control over money and eventual beneficiary(ies)

  • Trust set up is semi-complicated
  • Investment amount usually limited to Nil Rate Band
  • Must survive for 7y

The FRTs (Flexible Reversionary Trust) are effective for IHT planning purposes…

With the variety of arrangements available for inheritance tax (IHT) mitigation, there has been great debate on what to recommend to clients who are worried about IHT ravaging their estate.

In terms of packaged products, most think they broadly have a choice between a discounted gift trust – which is effective in mitigating IHT but slightly restrictive and subject to underwriting – or a gift & loan trust, which is not hugely effective for IHT planning purposes. Although the latter does allow the client access to the amount loaned.

There is another method however which we consider to be a mix of both worlds.

The FRTs (Flexible Reversionary Trust) are effective for IHT planning purposes and are versatile in meeting the client’s income needs.

Traffic light comparison

Whole of Life
Loan Trust
Discounted Gift Trust
Flexible Reversionary Trust
Business Property Relief
How each of the solutions fare in relation to these issues is indicated above using a traffic light system; green being the most favourable.

Please note: this graphic is subjective to change, not every expert will agree on the distribution of colours. There is much more to know before you act and that you should always seek financial advice first.

Designed to allow individuals to make a gift of capital whilst retaining periodic access to cash…

The FRT has been designed to allow individuals to make a gift of capital whilst retaining, in a flexible and IHT efficient way, periodic access to cash if needed.

We hope the investment will grow and so the settlor may be liable to some tax on maturities. On death of the last life assured (you can have several), the gains will become chargeable and subject to tax.

This is achieved by combining single premium life assurance policies with a sophisticated reversionary interest trust.

The discretionary settlement has an added advantage in that the actual beneficiaries do not have to be specified until the time comes, with just classes of beneficiaries (such as children and grandchildren) being listed initially.

Flexible Reversionary Trusts for IHT Planning (in practice)…

This is one of our favoured solutions as it provides an option to receive money back at the end of each year, which is IHT planning gold.

You will require liquid assets and a few more miles left on the clock.

The payment to such a plan is known as a Chargeable Lifetime Transfer (CLT) which means that it is likely to be exempt from IHT after 7 years of survival.

In more detail, so long as the investment is below your Nil Rate Band (when added to other CLTs from the last 7y) of £325,000 in 2024/25, you will not pay any initial tax on the gift. There may be periodic or exit charges.

TAKE CARE – As so long as you survive 7y there will be no IHT on death; however, it can affect the tax treatment of other gifts.

TAKE CARE II – It must be said, however, that Periodic and Exit charges can still apply, so planning is important. Even if the CLT does not incur an IHT charge itself, it may affect the tax treatment of further CLTs made up to 7 years after the original gift.

As you have read above, you can access large amounts of the investment each year. This is really important as access to funds is one of the most undervalued tools in IHT planning.

Should you live longer than expected or need more than is expected, you want to know that there are funds that can be utilised. Like with Business Property Relief qualifying investments, FRTs are one of very few tools that fit the bill.

The investment is split in to a chosen number of maturities which define your maximum annual draw back from the investment. The maturities occur from the end of year one and can be best defined as providing a ‘look at the money.’

When the policies mature, the proceeds are available to be drawn back out for your own use. You can draw between £0 and a full maturity each year, if required (typically, we set each FRT up to have 7-10 maturities; in these instances you could have an option to draw a 10th or a 7th of the plan value each year).

You can extend policy maturity dates should the money not be required, so it would instead be available in future years.

These yearly payments are optional and for best IHT planning practice should only be drawn from the plan when there are no other assets available that are still within your taxable estate or when they can be spent (or otherwise leave the estate).

IHT Planning is best dealt with holistically, taking into account all of your finances and goals

We have many years of experience in advising clients across the country who wish to protect their estate, and we provide a tailored service for each individual. Our company is well qualified to answer questions and enable you to organise your assets.

If you have any questions or queries call us on: 0800 093 4115


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