Transfer of unused RNRB: The ‘brought-forward’ allowance
The brought-forward allowance is the residential nil rate band (RNRB) that was unused on the earlier death(s) of a spouse(s) or civil partner(s). If there is any unused RNRB, it can be added to the RNRB of the surviving spouse, or civil partner, when they die.
The brought-forward allowance is calculated as a percentage of the residential enhancement (IHTM46022) on that earlier death. 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 multiplied by the residential enhancement at the date of the survivor’s death. Once calculated this is simply added to the surviving spouse, or civil partner’s, RNRB in determining their default allowance (IHTM46024).
For deaths before 6 April 2017
The maximum the brought-forward allowance is 100% of the residential enhancement. For deaths before 6 April 2017 the residential enhancement is deemed to be £100,000 (IHTA84/S8G(4)). Much the same as for TNRB, it is available regardless of:
- when the earlier death took place,
- how much the estate was worth as long as the taper threshold has not reduced the available allowance to nil, and
- whether or not it included a residence.
For deaths before 6 April 2017, as there was no RNRB, the brought-forward amount will be 100% of the residential enhancement in force at the later death of a spouse or civil partner. The only factor that might reduce this 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
The maximum the brought-forward allowance can be is 100% of the residential enhancement. Again, there is no minimum value an estate must be 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 is exceeded, or by the value of any RNRB used if there was a residence in their estate that was closely inherited. Any unused RNRB will be available to carry-forward.