Looking for views on whether double taxation on IHT will lead to long delays at HMRC

While the proposals are designed to prevent double taxation in theory, in practice many clients are likely to experience it that way. Where pensions fall into the IHT net and beneficiaries also pay income tax on withdrawals (particularly post-75 deaths), the combined effective tax rate can be very high—even if technically the same funds aren’t taxed twice.

The bigger concern is operational. Introducing pensions into the IHT framework creates a complex, multi-party process involving personal representatives, pension schemes and HMRC. Timing mismatches—especially around valuations and payment deadlines—make overpayments and subsequent reclaims quite possible.

As a result, delays, administrative friction and increased interaction with HMRC are likely, particularly in the early years. Unless guidance and systems are exceptionally clear and well coordinated, there is a real risk this will be challenging to administer in practice.