Medium2 marksMultiple Choice
Inheritance TaxSection BIHTRNRBDownsizing

ACCA · Question 24 · Inheritance Tax

Section B: Case 2 - Eleanor Vance

Scenario: Eleanor Vance, a wealthy agricultural landowner, made several lifetime transfers before her death on 12 November 2023. On 15 August 2021, she transferred £450,000 of cash into a discretionary trust. Eleanor paid the lifetime Inheritance Tax (IHT) arising on this transfer. She had made no previous lifetime gifts.

Question: Eleanor's estate at death was valued at £1.8 million. She left her entire estate to her children. In 2020, she had sold a large main residence (valued at £600,000) and moved into the smaller farmhouse (valued at £250,000).

Assuming all conditions are met, what is the maximum Residence Nil Rate Band (RNRB) available to her estate for 2023/24?

Answer options:

A.

£250,000

B.

£175,000

C.

£350,000

D.

£0

How to approach this question

Identify the standard RNRB limit for 23/24 (£175,000). Check if the estate exceeds the £2m taper threshold. Check if the property value covers the RNRB.

Full Answer

B.£175,000✓ Correct
For the tax year 2023/24, the maximum Residence Nil Rate Band (RNRB) is £175,000. Eleanor's estate is £1.8 million, which is below the £2 million threshold where the RNRB begins to taper away. She left her home to direct descendants (children). The current home is worth £250,000, which is more than the £175,000 limit, so the full £175,000 is available. The downsizing rules are not even needed here to get the full allowance, but if the farmhouse had been worth £100,000, the downsizing addition (from the sale of the £600,000 home) would have topped up the allowance to the £175,000 maximum. The maximum available remains £175,000.

Common mistakes

Assuming the downsizing addition allows the RNRB to exceed the £175,000 statutory limit.

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