We’ve summarised the IHT information sharing requirements for pension scheme administrators and personal representatives/prospective personal representatives along with deadlines that come into force, for deaths that occur on or after 6 April 2027 in the table below.

Abbreviations:

  • PSA – Pension Scheme Administrator
  • PR – Personal Representative
  • PPR – Prospective Personal Representative

Note – the requirements for insurance companies are similar but we’ve not covered them here.

Trigger:Who should provide the info:Provide info to:What is required?Deadline
On request from PR/PPR following the member’s death.PSAPR/PPR
  1. the scheme name and scheme administrator’s contact details (name and address),
  2. any reference number allocated to the member,
  3. whether the scheme is an investment‑regulated pension scheme (e.g. a non-occupational pension scheme where the member can choose their own investment funds)
  4. the value of the member’s notional pension property at the date of death (excluding ‘Excluded benefits’),
  5. whether that value is provisional estimate, and the reasons if so, and
  6. how the value will be allocated between exempt and non‑exempt beneficiaries.

 

For 1-5 - within 28 days of request.

For 6 – the later of 28 days from request or 14 days after beneficiaries have been determined in accordance with scheme rules.

If the value provided is provisional the final value must be supplied within 14 days of being ascertained.

Note – the 28-day period starts once the PSA has verified that the individual has authority to act as PR/PPR and has completed the identity verification process. 

 (HMRC’s Technical note 2 confirms this in  3.2)

Trigger:Who should provide the info:Provide info to:What is required?Deadline
On request from the PR/PPR where they are required to file an IHT account.PSAPR/PPRThe scheme administrator must provide:
  • Scheme name and PSA contact details (name and address),
  • Any member reference number,
  • Beneficiary details: names, addresses, and (if applicable/known) National Insurance numbers,
  • For trust beneficiaries the name of the trust and names and addresses of trustees,
  • The value and percentage share of notional pension property attributable to each beneficiary.
  • Details of excluded benefits that have been paid or are intended to be paid, including:
    • Dependants' scheme pensions;
    • Trivial commutation lump sum death benefits derived from dependants' scheme pensions;
    • Dependants' or nominees' annuities purchased in connection with a lifetime annuity;
    • Death-in-service payments; and
  • Where any excluded benefits have been or are intended to be paid, the administrator must specify the type of payment and provide:
    • The initial annual rate of any dependant's pension or annuity; and/or
    • The amount of any death-in-service payment.

Information must be provided by the later of:

  • 28 days from receipt of the request; or
  • 14 days after all beneficiaries have been determined in accordance with the scheme rules.

 

Trigger:Who should provide the info:Provide info to:What is required?Deadline
Where the PR/PPR submits a withholding noticePSAPR/PPRInitial obligation:
  • Acknowledge receipt of the notice,
  • Confirm whether it’s been accepted as a valid notice,
  • If not accepted as a valid notice, provide the reason why.

Further obligation for valid notices:

  • Total amount being withheld,
  • Whether or not this is an estimate of the notional pension property,
  • Where the beneficiaries have been determined:
    • The name of each beneficiary, and
    • The amount withheld in respect of each beneficiary

 

 

Initial obligation - within 14 days of receipt of the notice.

 

 

 

 

Further obligation - within 28 days of receipt of a valid notice.

Where the PP/PPR submits a withholding notice and the notice has not been determined as invalid, and some or all of the deceased’s pension rights are, or are due to be, transferred to another pension scheme or insurance company.

PSA of transferring scheme

PP/PPR

  • The name of the receiving scheme or insurance company,
  • The name and address of the new PSA,
  • Date of transfer.

The later of:

  • 14 days from the date of transfer to the new scheme, and
  • 14 days from the date the withholding notice is given.

Where the PR/PPR submits a withholding notice and the PSA accepts it as a valid notice

PSA

Beneficiaries

  • Date of receipt of the withholding notice
  • The name, address and any other contact details held for the person who gave the notice.
By the later of:
  • 14 days of receipt of the notice, or
  • 4 days after beneficiaries have been determined.

Where a person only becomes a beneficiary after a withholding notice has been received, the information must be provided within 14 days of that person becoming a beneficiary.

Trigger:Who should provide the info:Provide info to:What is required?Deadline
Where a PSA makes a payment of IHT (plus any interest) following receipt of a payment notice from a beneficiaryPSABeneficiary
  • Deceased’s name and date of death,
  • IHT reference number,
  • Amount of IHT paid (with any interest paid identified separately),
  • Date of payment and HMRC payment reference,
  • Confirmation that the beneficiary’s entitlement to benefits has been reduced by the amount paid to HMRC.
Within 14 days of the payment being made.
Where a PSA makes a payment of IHT (plus any interest) following receipt of a payment notice from a beneficiary

 

PSAPR
  • Deceased’s name and date of death,
  • IHT reference number,
  • Amount of IHT paid (excluding interest) and amount of interest paid,
  • Date of payment and HMRC payment reference,
  • Details of the beneficiary who gave the payment notice – name and address.
Within 14 days of the payment being made.

Trigger:Who should provide the info:Provide info to:What is required?Deadline
Where a PSA makes a payment of IHT (plus any interest) following receipt of a payment notice from the deceased’s PRs (Note – PPRs cannot submit payment notices)PSAPR
  • Member details – name and date of death,
  • IHT reference number,
  • Amount of IHT paid (excluding interest) and amount of interest paid,
  • Date of payment and HMRC payment reference,
  • Confirmation of the reduction in each beneficiary’s share of the notional pension property, to the extent known,
  • If beneficiaries have not yet all been determined, the total reduction in the notional pension property resulting from the payment.

Within 14 days of the payment being made.

Where a PSA makes a payment of IHT (plus any interest) following receipt of a payment notice from the deceased’s PRs and a beneficiary’s entitlement is reduced as a result.  (Note – PPRs cannot submit payment notices)PSABeneficiary
  • The scheme administrator must provide each affected beneficiary with:
  • Name of the scheme member,
  • Date of death of the member,
  • IHT reference number,
  • HMRC’s payment reference,
  • Name and address of the personal representative who gave the payment notice,
  • Amount of IHT paid on behalf of that beneficiary, and
  • Amount of any interest paid on that beneficiary’s behalf.
Within 14 days of the payment being made, but where beneficiaries are determined after the payment of IHT, within 14 days of becoming a beneficiary under the scheme rules.

Trigger:Who should provide the info:Provide info to:What is required?Deadline
Once the final payment of a death benefit lump sum is made.PSAPRInformation which must be provided automatically:
  • The name of the pension scheme,
  • The name and address of the PSA,
  • Any relevant reference numbers for the deceased member and
  • Total amount of the lump sum death benefit paid.

Additional information that must be provided if PR requests it:

  • 1. Who received the death benefits. For each beneficiary:
    • Name,
    • Address,
    • Date of birth, and
    • NI number (if applicable and known).
  • 2. What each beneficiary received. For each beneficiary:
    • The amount of the deceased member’s LSDBA used up by the payment,
    • Amount of the payment made to them, and
    • The date the payment was made.
  • 3. Any inheritance tax adjustment. For each payment the PSA must confirm the amount (if any) by which the beneficiary’s lump sum death benefit was reduced because inheritance tax was paid under the direct payment scheme to HMRC.

 

Automatic information - within 3 months of the date of making the final death benefit payment

 

 

 

 

Additional information - within 1 month of receiving the request from the PR.

 

 

 

 

 

 

 

Following the final payment of lump sum death benefits where the PR concludes that the deceased member’s LSDBA has been exceededPR/PPRHMRCThe PR must provide the following to HMRC:
  • Deceased’s name, date of birth, date of death and NI number,
  • Details of their pension schemes (Scheme name, name and address of PSA),
  • Each relevant reverence number,
  • Details of the beneficiaries who received lump sum death benefit payments (name, address, date of birth and NI number),
  • Amounts of lump sum death benefit paid to each beneficiary and dates of payments,
  • IHT paid directly by the pension scheme from each of the lump sum death benefits (if any).
By the later of:
  • 13 months after the date of death, and
  • 2 months after the date on which the PR becomes aware that the allowance has been exceeded.