Executive Summary: Addressed directly to the boomer generation, this article provides the practical solution framework for protecting pension wealth across generations despite the April 2027 reforms. It introduces the two-trust structure: a standard insurer trust to receive whole of life payout on first death, combined with a separate lifetime family trust (the “IHT Pool”) that holds proceeds outside both estates. Includes a worked example showing Mr Miggins’ £1 million IHT liability being met.

For decades, pensions sat outside inheritance tax. The advice was simple: preserve the pension, spend other assets first, pass pension wealth to the next generation tax-free. Thousands of families planned exactly that way.

From April 2027, unused defined contribution pensions fall inside the inheritance tax framework. Here is what that means for you.

Why This Matters

I am in my 60s. My boomer peers retired with pensions from the golden age of workplace schemes. Final salary. Defined benefit. Generous accrual rates that rewarded decades of loyal service.

Our children will not have the same fortune. There are no 60th accrual final salary schemes waiting for them. The line manager at JLR with a £600,000 pension fund built over a career — that outcome is simply unreachable for millennials, for Gen Z, for most of Gen X.

It is entirely natural to want to share that good fortune. To want to pass on what you have built over a lifetime. And it would be a travesty to see a lifetime of disciplined saving lost to inheritance tax when there are legitimate, well-established ways to prevent exactly that.

The Risk

The third part of this trilogy showed that the combined effect of inheritance tax, the residence nil rate band taper, and income tax on pension drawdown can mean up to 87.2% of a pension fund lost to tax. In some cases, it reaches 90%.

Almost ninety pence of every pound going to HMRC instead of to your children and grandchildren.

That is not a theoretical risk. It is a mathematical certainty for families in a specific set of circumstances — circumstances that are far more common than the press or the government would have you believe.

The Solution

There are four steps. They must be taken in the right order.

  1. Set up a whole of life policy now, while you are in good health. Not an over-50s plan from a television advert. A properly underwritten whole of life policy. Your health is your biggest asset in this process. Once it changes, options reduce or disappear entirely.
  2. Check your pension nomination — and update it for the April 2027 reality. The default option of “leave everything to my spouse” may turn out to be the most expensive decision you ever make. It needs to be reviewed in the context of both estates, both tax positions, and the new rules.
  3. Use your pension to fund the whole of life policy. Purchase an annuity from your pension fund and use the annuity income to pay the premiums on the whole of life policy. This immediately begins to take capital out of your estate. But it only works if the whole of life policy is already in place first.
  4. Structure the trusts correctly. This is where most advice falls short.

But This Only Works If You Set Up Two Trusts, Not One

Most advisers who arrange whole of life insurance will write the policy into the insurer’s standard trust. That is normal practice. It is also not enough.

You need a second trust — a lifetime trust. A separate, standalone discretionary or flexible trust that sits alongside the insurer’s trust. We call this the “IHT Pool.”

This is the protected fund. The fund that exists specifically for paying inheritance tax, helping the surviving spouse, and keeping the estate stable when it matters most.

Why Two Trusts?

When the first spouse dies, the whole of life policy pays out. That payout lands in the insurer’s standard trust. The trustees of that trust then immediately pass the proceeds to the family lifetime trust — the IHT Pool.

The money is now outside both estates. It is protected. It is available. And it is there for when the real inheritance tax liability crystallises — on the second death.

This structure buys time. No forced sales. No panic. No fire-sale of the family home or the business to meet a tax bill within six months of death.

It gives control. The terms are agreed in advance. The trustees know what to do. The family knows the plan.

Worked Example: Mr and Mrs Miggins

Mr Miggins is the older spouse. Mrs Miggins is younger. Their combined estates produce an inheritance tax liability of £1,000,000.

Mr Miggins dies first.

  • The whole of life policy pays out £1,000,000
  • The payout lands in the insurer’s standard trust (Trust 1)
  • The trustees of Trust 1 move the £1,000,000 to the lifetime family trust (Trust 2 — the IHT Pool)
  • The money is now outside both estates
  • It is available to meet the IHT liability on the second death
  • It prevents the forced sale of the family home or business
  • It supports multigenerational planning
The surviving spouse has time, stability, and liquidity. The children inherit a structure, not a problem.

Why This Requires Proper Advice

This is not an over-50s plan. It is not something you arrange online in fifteen minutes.

It requires:

Most advisers can arrange a policy and a standard trust. But the standard approach was not designed for family wealth planning across generations. It was designed for simple cases. Your case is not simple.

If This Describes Your Situation

Your intention to leave your pension to your children can still be achieved. The route has changed, but the destination has not.

Structure matters more than ever. April 2027 is not the end of pension inheritance planning. It is the start of a different kind of planning.

The tools exist. The legislation supports it. But the planning needs to be done properly, and it needs to be done now — while health allows, while time permits, and while the full range of options remains available.

Technical Reference

Key legislation: IHTA 1984 s21 (normal expenditure out of income exemption). Finance Act 2004 Part 4 (annuity purchase from defined contribution pension). Finance Bill 2025–26 (pension inclusion in IHT from April 2027). Trustee Act 2000.

Two-trust structure: Trust 1 (insurer’s standard trust — receives whole of life payout on first death) + Trust 2 (lifetime discretionary/flexible trust — the “IHT Pool” that holds proceeds outside both estates).

Key principles: Annuity purchase removes capital from the estate. Whole of life written in trust provides immediate liquidity outside the estate. Over-50s plans do not provide equivalent cover or flexibility. The two-trust structure ensures proceeds are protected on both deaths, not just the first.

External references:

HMRC: Normal expenditure out of income (s21)

HMRC consultation: Inheritance tax on pensions

Understand Your Pension IHT Exposure

Use our free IHT calculator to see how the April 2027 pension changes affect your estate, or get an instant whole of life quote to protect your family’s inheritance.

About the Author

Stephen Hunt ACII is a Chartered Insurance Risk Manager and STEP Affiliate, specialising in inheritance tax risk management for farmers and family business owners. With deep expertise in the intersection of IHT legislation, insurance solutions, and estate planning, Stephen helps families protect generational assets against the impact of inheritance tax. He is the founder of IHT Solutions.