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HMRC internal manual

Inheritance Tax Manual

Pre-owned assets: unwinding of home loan or double trust scheme: residence nil rate band

Residence nil rate band (RNRB) (IHTM46000) will normally be available on death so long as the property, or part of it, now passes to a direct descendant (IHTM46034). Where the scheme (IHTM44103) is only partially unwound, with the debt having been appointed back to the settlor, the debt will form both an asset of the settlor’s estate and a liability of the trust. Only the net value of the trust will reflect any value for the property in the deceased’s estate, and where the value for the debt is equal to the value of the property no RNRB will be due.