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HMRC internal manual

Inheritance Tax Manual

Transfer of unused RNRB: The ‘brought-forward’ allowance

The brought-forward allowance is the residence nil rate band (RNRB) that was unused on the earlier death of a spouse or civil partner. If there is any unused RNRB, it can be added to the RNRB available to the survivor’s estate when they die.

The maximum brought-forward allowance is expressed as a percentage, which cannot exceed 100%.

The brought-forward allowance is calculated as the unused percentage of the residential enhancement (IHTM46022) on that earlier death. For deaths before 6 April 2017 the residential enhancement at that time is deemed to have been £100,000 (IHTA84/S8G(4)).

It is possible to transfer unused RNRB from more than one pre-deceased spouse or civil partner by adding together all of the brought-forward allowance percentages, but the total percentage is limited to 100%.

The total percentage is then multiplied by the residential enhancement at the date of the survivor’s death. Once calculated this is simply added to the survivor’s RNRB in determining their default allowance (IHTM46024).

Much the same as for transferable nil rate band (IHTM43001), the transferrable element is available regardless of:

  • when the earlier death took place,
  • how much that earlier estate was worth, as long as the taper threshold does not reduce the available allowance to nil, and
  • whether or not it included a residence.

For deaths before 6 April 2017.

For deaths before 6 April 2017, as there was no RNRB at that time, none can have been used. The brought-forward amount will be 100% of the residential enhancement in force at the later death of the surviving spouse or civil partner. The only factor that might reduce the brought-forward amount is if the earlier estate value was greater than the £2,000,000 taper threshold, in which case the tapering provisions will apply (IHTA84/S8G(5)) (IHTM46023).

For deaths on or after 6 April 2017

For deaths on or after 6 April 2017 , as RNRB was available it is possible that some or all of the available RNRB may have been used on the first death, reducing the unused amount which can be transferred. Again, there is no minimum value an estate must have been worth, and there is no requirement that it included a residence. However, the value of the unused RNRB on the first death may be reduced by the tapering provisions if the taper threshold was exceeded, or by the value of any RNRB used if there was a residence in their estate that was closely inherited. The brought-forward amount takes these factors into account.