Inheritance Tax liabilities statistics: commentary
Published 31 July 2024
1. Key points
The key points from this year’s publication are:
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in the tax year 2021 to 2022, 4.39% of UK deaths resulted in an Inheritance Tax (IHT) charge, increasing by 0.66 percentage points since the tax year 2020 to 2021. This means that IHT is payable on fewer than 1 in 20 estates, as it has done since 2007 to 2008, and broadly since statistics were first produced. This proportion is now at its highest level since the 2016 to 2017 tax year
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the total number of UK deaths that resulted in an IHT charge has increased. In the tax year 2021 to 2022, there were 27,800 taxpaying IHT estates, an increase of 800 (3%) since the previous tax year, 2020 to 2021. Fewer than half of all deaths in any given year require interaction with HMRC to establish whether there is a liability to be paid
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IHT liabilities created in respect of the tax year 2021 to 2022 were £5.99 billion. This was a rise of £0.23 billion (4%) compared to the previous year. The rise in IHT liabilities created compared to previous years is likely due to a combination of higher volumes of wealth transfers following recent IHT-liable deaths, recent rises in asset values, and the government’s March 2021 and Autumn 2022 decisions to maintain the IHT tax free thresholds at their 2020 to 2021 levels up to and including 2027 to 2028. More information on these decisions is available in the policy papers accompanying the Budget 2021 Finance Bill and the Autumn Finance Bill 2022
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the largest exemption set against assets continues to be for transfers between spouses and civil partners. In the 2021 to 2022 tax year, £15.5 billion was transferred to surviving spouses and civil partners on death, a fall of £0.2 billion (1%) on 2020 to 2021. This exemption was used by 21,800 estates above the nil-rate band (NRB) in the tax year 2021 to 2022
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the combined value of agricultural and business property relief (APR, BPR) was £4.4 billion in the tax year 2021 to 2022. This was an increase of £0.2 billion (5%) compared to 2020 to 2021. While the value of BPR fell by £0.4 billion (11%), the value of APR rose to more than offset this, by £0.6 billion (54%)
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the value of exempted transfers to qualifying charities also increased, to £2.1 billion in the tax year 2021 to 2022 from £1.8 billion in the tax year 2020 to 2021
2. About this release
This publication contains statistics on Inheritance Tax (IHT) and estates passing on death where an IHT form was sent to HMRC as a grant of representation was required. Statistics relating to the composition of estates, to the use of reliefs and to the tax due on estates are provided for estates passing on death in the 2021 to 2022 tax year. Information is also provided on trusts paying IHT trust charges.
Further information on IHT rules, tax rates, reliefs and exemptions are available in the Inheritance Tax guidance.
Following a reporting requirement change from 1 January 2022, non-taxpaying estates which are classed as ‘excepted’ are no longer required to report their valuations to HMRC. As a consequence, their details are no longer included in these statistics, which now have slightly reduced coverage. For more information, please see the policy paper announcing the changes.
IHT receipts received by HMRC during a particular financial year are no longer reported in this publication. Please see HMRC’s monthly and annual bulletins on tax receipts for the latest commentary on the trend in IHT receipts received by HMRC.
These publications report the cash receipts received by HMRC in a given month or year. In some limited circumstances, IHT can be paid by transferring assets under the ‘acceptance in lieu’ scheme. Receipts under this scheme are reported by the Office for National Statistics (ONS) in their National Accounts.
3. Coronavirus (COVID-19)
This publication refers to tax years that include the effect of the COVID-19 pandemic. In particular, the statistics provided for the 2020 to 2021 and 2021 to 2022 tax years include wealth transfers that resulted from deaths caused at least in part by COVID-19.
4. IHT liabilities and taxpaying estates
Figure 1: IHT liabilities, tax year 2001 to 2002 to tax year 2021 to 2022
4.1 Liabilities
Figure 1 shows that there was a 4% (£230 million) increase in tax liabilities created between the 2020 to 2021 and 2021 to 2022 tax years, with liabilities standing at £5.99 billion in 2021 to 2022.
Tax liabilities are now at their highest level on record, surpassing the previous peak of £5.76 billion in the 2020 to 2021 tax year.
The rise in IHT liabilities created in the 2021 to 2022 tax year is likely due to a combination of higher volumes of wealth transfers following recent IHT-liable deaths, continued rises in asset values, and the government decision to maintain the IHT tax free thresholds at their 2020 to 2021 levels until April 2028.
There is a delay between death (when the tax charge is created) and when a tax payment becomes due at least six months later. Executors’ decisions regarding when to pay any outstanding tax can therefore influence the receipts received by HMRC in a given financial year. IHT can also be paid in instalments.
4.2 Number and proportion of deaths resulting in an IHT charge
Figure 2: Number and proportion of deaths resulting in an IHT charge
Figure 2 shows that in the tax year 2021 to 2022, 4.39% (27,800) of UK deaths (634,000) resulted in an IHT charge, increasing by 0.66 percentage points since the previous tax year, 2020 to 2021. This proportion is now at its highest level since the 2016 to 2017 tax year.
Between the 2017 to 2018 and 2020 to 2021 tax years, the proportion was relatively flat - likely as a result of the introduction of a new tax-free allowance known as the residence nil-rate band (RNRB) from the 2017 to 2018 tax year onwards. The RNRB is available to those estates that transfer their main UK residence to direct descendants on their death. It was phased in over time, increasing in £25,000 increments until it reached its target value of £175,000 in the 2020 to 2021 tax year. It has since been maintained at that level up to and including the 2027 to 2028 tax year.
It is likely that the rise in the generosity of the RNRB between the 2017 to 2018 and 2020 to 2021 tax years broadly offset the impact of rising asset prices, leaving the proportion of estates subject to an IHT charge broadly flat in recent years.
Both the number and proportion of estates resulting in an IHT charge is still below the all-time high of 34,100 (5.96% of all UK deaths) seen in the tax year 2006 to 2007, and the more recent high of 28,100 (4.62% of all UK deaths) seen in the tax year 2016 to 2017.
4.3 Liable estates and average tax paid
Table 12.1 breaks down the average tax bill by net estate size. It shows that the average tax bill for taxpaying estates rises as the size of the net estate rises. Those 2,210 taxpaying estates valued at between £300,000 and £400,000 paid £13,500 in IHT on average, whereas those 170 taxpaying estates valued at more than £10 million paid £3.91 million on average.
The average amount of IHT paid across all taxpaying estates has increased slightly by just under 0.5% (£1,000) between the tax years 2020 to 2021 and 2021 to 2022, and now stands at £215,000. Since the tax year 2017 to 2018, the average tax bill has increased markedly. These large increases are likely to be explained by the effects of the RNRB’s introduction.
This new tax-free threshold was first introduced in the 2017 to 2018 tax year, where it was worth £100,000 to qualifying estates, and has been phased in in stages since then. Since its introduction, the availability of the RNRB to qualifying estates has meant a number of estates which beforehand would have paid a relatively small amount of tax no longer did so. This meant that those estates which remained taxpaying transferred larger amounts of wealth on average – increasing the average tax paid by those remaining taxpaying estates.
4.4 Average effective tax rates (AETRs) for taxpaying estates
Information on AETRs in this publication
For more information about AETRs and how they have been calculated, please see the tax rates section of the background quality report accompanying these statistics.
The tax year 2021 to 2022
Despite the headline marginal rate of IHT being 40%, the AETR for the 2021 to 2022 tax year was lower, at 13%, for all 27,800 taxpaying estates; around one-third of the headline rate. This is due to the combination of tax-free allowances, exemptions, and reliefs used by taxpaying estates to minimize the chargeable portion of their estate.
However, the AETR varied according to the size of the estate being taxed, as Figure 3 shows.
Figure 3: Average effective tax rate (AETR) for taxpaying estates, tax years 2016 to 2017 up to and including 2021 to 2022
Figure 3 shows the AETR was lower for smaller taxpaying estates. While there were 2,210 taxpaying estates with a net estate value between £300,000 and £400,000, the AETR paid by this group in the tax year 2021 to 2022 was 4%, with an average tax bill per estate of £13,500.
Figure 3 shows the AETR rose gradually as the value of the net estate rose, reaching 13% for estates valued at between £1 million and £1.5 million. There were 6,770 such estates in this band, with an average tax bill of £155,000.
The main reason the AETR rises gradually is that many estates valued between £300,000 and £1 million benefit from various combinations of tax-free allowances. While all estates benefit from the NRB, worth £325,000, some estates may benefit from further tax-free allowances depending on the marital status of the deceased, and whether the deceased qualifies for the RNRB. This means that some estates can transfer up to £1 million before tax becomes due on any estate value in excess of this amount. For more information, please see the section on IHT thresholds and nil-rate bands in the background quality report.
For estates valued at more than £1.5 million but less than £2 million, Figure 3 shows the AETR rose to 19%, and the 2,460 estates in this band paid an average of £325,000. This was likely due to these estates exhausting their available tax-free allowances, with a greater share of their estates being subject to tax than estates that are smaller.
As soon as an estate becomes at least £2 million in size, the RNRB starts to be tapered away, at a rate of £1 for every £2 that the estate exceeds the £2 million taper point. This happens even if a home is left to direct descendants. For many estates, as soon as an estate is worth £2.7 million or more, no RNRB can be used. This is one reason why the AETR for taxpaying estates valued at between £2 million and £7.5 million was larger, at an average of 24% in the 2021 to 2022 tax year. There were only 2,871 such estates.
Figure 3 shows the AETR for the largest taxpaying estates in 2021 to 2022 was lower than for those estates valued at between £2 million and £7.5 million – at 22% and 20% respectively for estates valued at between £7.5 million and £10 million, and above £10 million. This is because such estates often make proportionately greater use of available exemptions and reliefs, such as business property relief, than those estates that are smaller. There were only 282 estates that fell into these two bands. While facing a proportionately lower AETR, the taxpaying estates in those bands paid the highest average tax bills by value of all taxpaying estates - at £1.90 million and £3.91 million respectively.
Comparison with earlier tax years
Figure 3 also includes the AETRs for the tax years 2016 to 2017 up to 2020 to 2021.
Figure 3 shows that:
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while there is some variation in the level of AETRs depending on the tax year, all tax years in this period display a similar trend. Within a given tax year, the AETR tends to be low at around 4% for net estates valued at between £300,000 and £400,000, before rising gradually
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for the tax year 2016 to 2017, after a net estate reaches at least £800,000 in value, the AETR tends to increase more quickly, reaching around 20% and 25% for net estates valued at between £1 million and £1.5 million and £1.5 million and £2 million respectively
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for the tax years between 2017 to 2018 and 2020 to 2021, the point at which the AETR starts to increase more quickly is in higher net estate bands – when a net estate is valued at between £900,000 and £1 million. This difference across years is likely due to the effects of the RNRB’s introduction, since the RNRB allowed lower value estates to reduce the chargeable portions of their estates
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for all tax years in the period, the AETR then tends to increase to around 25% for estates valued at between £2 million and £7.5 million. The AETR tends to fall slightly for the largest estates worth more than £7.5 million – likely due to those estates’ proportionately greater use of reliefs and exemptions
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annual variation is likely to occur depending on the composition of estates transferring wealth each year, and particularly depending on the marital status of the deceased. This will impact the size of the tax-free allowance that each estate could benefit from
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in particular, the RNRB was phased in over time from the tax year 2017 to 2018 onwards, meaning that in each subsequent tax year, some estates would benefit from a different maximum combination of tax-free allowances, if they were eligible. This was between £850,000 and £1 million, depending on the tax year, and so will impact the AETRs in those tax years for particular net estate bands. Please see the background quality report accompanying these statistics for more information
5. Use of exemptions and reliefs
Table 12.2 shows the use of exemptions and reliefs by estates requiring a grant of representation for which the net capital value of the estate lies above the NRB (including TNRB where this applies). The value of the relief or exemption is equal to the total amount claimed against assets as opposed to the impact of that relief or exemption on an estate’s tax charge. Details of exemptions and reliefs are in the IHT account (IHT400) notes.
Many individuals structure their estates during their lifetimes in order to potentially benefit from reliefs and exemptions when they pass away and transfer wealth in future. The use of these reliefs and exemptions is not crystallised (i.e. does not occur) until the death occurs. For all reliefs and exemptions, differences across years are likely due to:
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differences in the number and cohort of deaths requiring probate (known as confirmation in Scotland) across tax years
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differences in the wealth distribution and asset structures of those estates across tax years
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differences in the claims made for reliefs and exemptions by those estates across tax years
It is therefore not unusual for the value of reliefs and exemptions used when transferring wealth, as shown in these statistics, to differ markedly across years.
5.1 Spouse and civil partner exemption
The largest exemption set against assets continues to be for transfers between spouses and civil partners, valued at £15.5 billion in the 2021 to 2022 tax year and used by 21,800 estates. This was a fall of £0.2 billion since the tax year 2020 to 2021.
This exemption was taken advantage of by 34% of estates above the NRB but was worth 68% of the total value of reliefs and exemptions set against assets.
5.2 Agricultural and business property relief
The second largest relief set against assets was BPR, valued at £2.9 billion and used by 4,170 estates. This was a fall of £0.4 billion since the 2020 to 2021 tax year.
Combined, APR and BPR claimed against assets was £4.42 billion in the tax year 2021 to 2022, an increase of £0.2 billion on the tax year 2020 to 2021. The rise in APR granted more than offset the fall in BPR, with the value of APR rising by £0.6 billion to reach £1.6 billion in the 2021 to 2022 tax year, being claimed by 1,730 estates. This represented the highest number of APR claimants since the 2014 to 2015 tax year.
5.3 Exemption of transfers to qualifying charities and registered clubs
The next largest exemption set against assets was for transfers to qualifying charities or registered clubs. Such transfers were valued at £2.1 billion in the tax year 2021 to 2022 and were used by 9,780 estates.
This was a rise of £0.3 billion on the equivalent figure for the tax year 2020 to 2021.
5.4 Residence nil-rate band
The tax year 2021 to 2022 was the fifth year in which the new RNRB tax-free threshold could be used. This threshold provides an additional allowance to qualifying estates so that more wealth can be transferred to direct descendants before IHT could be due. Qualifying estates are estates which are transferring their main UK residence to their direct descendants. For more information on the eligibility criteria, please see HMRC’s RNRB guidance pages.
The threshold was set at £175,000 for the tax year 2021 to 2022, unchanged on the previous tax year (2020 to 2021) following the government’s decision in March 2021 to cancel the planned indexation. The RNRB had been phased in over time until it reached its £175,000 target in the tax year 2020 to 2021. Any unused amount can be transferred to a spouse or civil partner in the same way as the TNRB. This means that some couples had an effective RNRB threshold of £350,000 in the tax year 2021 to 2022, unchanged from 2020 to 2021.
In the tax year 2021 to 2022, 25,800 estates used the RNRB threshold, and £6.5 billion of chargeable estate value was sheltered from an IHT charge as a result. This was a rise of £0.4 billion compared to the tax year 2020 to 2021.
6. Composition of estates
Figure 4: Assets by range of net estate value, tax year 2021 to 2022
Figure 4 shows how the composition of assets changes between the various net estate bands, using information from Table 12.3a on the number of estates requiring a grant of representation and the composition of their estates by net estate value.
Where net estate value is less than £1 million, estates are likely to consist mainly of residential property and cash. Above this limit, estates are increasingly likely to consist of securities and other assets.
7. Characteristics of liable estates
7.1 Age
Table 12.5 shows the composition of taxpaying estates in the tax year 2021 to 2022 by asset type, gender, age, and marital status.
This table shows that taxpaying estates owned by those aged between 75 and 84 and 85 and over account for the vast majority of the tax liability. Those estates account for £1.5 billion (25%) and £3.4 billion (56%) of the total tax liability (£5.99 billion) for the tax year 2021 to 2022. Those aged under 75 or with unknown age account for only £1.1 billion (19%).
Around two-fifths of the value of taxpaying estates held by those aged under 65 at death is made up by their main UK residence. As the age of the deceased increases, so does their tendency to hold assets in cash and securities, as more of their accumulated wealth is no longer tied up in property. Those aged 45 to 64 hold around 23% of their wealth in securities, but this proportion increases to 32% for those aged 85 and over.
7.2 Gender
In the tax year 2021 to 2022, taxpaying male-owned estates had an overall tax liability of £2.93 billion, whereas taxpaying female-owned estates had a higher overall tax liability of £3.07 billion.
In general, female-owned estates tend to have slightly higher tax charges than those owned by males. This is likely due to the fact that females tend to have a higher life expectancy at birth than males. For instance, for the period 2020 to 2022 life expectancy at birth in the UK was 4 years longer for females, according to Office for National Statistics (ONS) Life tables. Females therefore have a higher probability of living longer than their spouse or civil partner (if applicable), and of leaving an estate on which the spouse and civil partner exemption cannot be claimed. Most marriages and civil partnerships in the UK tend to be between opposite-sex couples, as outlined by the ONS in their marriages in England and Wales release and their civil partnerships formations release, by the National Records of Scotland (NRS) in their marriages and civil partnerships release, and by the Northern Ireland Statistics and Research Agency (NISRA) in their births, deaths, and marriages release.
Male-owned taxpaying estates also had an average net estate of £1.3 million in the 2021 to 2022 tax year, slightly higher than the average net estate of female-owned taxpaying estates of £1.2 million.
7.3 Marital status
In the tax year 2021 to 2022, estates owned by deceased widowed individuals or deceased individuals who were a surviving civil partner, had an overall tax liability of £3.47 billion (58% of the total). Estates owned by deceased individuals with ‘other’ marital status (i.e. single or divorced individuals or individuals whose civil partnerships had been dissolved) had an overall tax liability of £2.13 billion (36% of the total). Estates owned by individuals who were married or in a civil partnership at the time of their death had a tax liability of £386 million (6% of the total).
Marital status is an important determinant of an estate’s IHT liability. If an individual is married or in a civil partnership at the time of their death, they can benefit from the spouse and civil partnership exemption when transferring wealth to their surviving spouse or civil partner. The use of this exemption is detailed in Table 12.2.
Assuming they do not transfer wealth to any other individuals and leave everything to their surviving spouse or civil partner, they also transfer any unused proportion of their NRB and RNRB if they are eligible. This means that the estates of widowed individuals or surviving civil partners can benefit from higher tax-free allowances when they themselves pass away and transfer wealth. More detail on these allowances and their eligibility criteria is set out in the background quality report accompanying these statistics.
Note, however, that the estates of married and civil partnership individuals can still pay IHT if they do not transfer all of their wealth to their surviving spouse or civil partner on their death.
8. Regional breakdown
Tables 12.8 and 12.9 show the number of estates resulting in a tax charge, and the total amount charged, by geographical region, defined in various different ways. Note that IHT is a tax based on the domicile of the deceased, rather than the reported residency status or location of their main UK home, and so regional breakdowns are provided for illustrative purposes only. For more information, please see the regional breakdown section of the background quality report accompanying these statistics.
By region, London and the South East of England have the highest numbers of estates passing on death which resulted in an IHT charge, at 4,540 and 5,860 estates respectively. These regions both accounted for £1.3 billion and £1.4 billion of the total tax liability created for the tax year 2021 to 2022 respectively. In the tax year 2021 to 2022, 53% of the IHT liability for England was concentrated in these regions alone - the average taxpayer in London was charged £275,300. London and the South East account for 45% of the total IHT charged across the UK.
By contrast, the lowest number of taxpaying estates were found in the North East of England, Northern Ireland, and Wales. This may have been attributed to lower house prices in those regions, and therefore the lower values of wealth transfers that fell above the tax-free allowances that triggered a tax charge.
9. Trusts
9.1 About IHT trust charges and these statistics
IHT is also due on assets within certain trusts whenever a chargeable event occurs. This could be when assets are transferred into or out of a trust, where an entry or exit (also known as ‘proportionate’) charge may be due, or on the ten year anniversary of a trusts’ creation, where an anniversary charge may be due. More details on trusts and IHT charges for trusts can be found on the Trusts and Taxes guidance.
Tables 12.7a, 12.7b and 12.7c show the number of IHT trust charges, as well as the total tax liability due on those charges. These statistics are shown for the tax year 2009 to 2010 to the tax year 2022 to 2023. Some volatility around these figures is to be expected due to relatively small numbers and because charges are due for different trusts in different tax years. It is also possible for trusts to face several types of charge in a given tax year, and so could appear in multiple tables, or multiple times within the same table, depending on the number of chargeable events that take place. For instance, if a trust made several taxable exits in a particular tax year, then each of those exits would result in a separate exit charge, and that trust would appear several times in the relevant table. Therefore, caution must be used when interpreting these statistics.
Information for the most recent years is deemed to be incomplete because of delays in submitting accounts; therefore, complete information is not available for some time after the chargeable event. The estimates for tax years 2020 to 2021, 2021 to 2022, and 2022 to 2023 should therefore be used with caution as they may not represent the total population. Estimates will be subject to further revisions in the next publication (scheduled July 2025) as more information becomes available. The majority of trusts are non-taxpaying due to the tax-free threshold and are not included in these statistics.
9.2 Changes to these statistics
Following a consultation on changes to HMRC statistics, we now publish information about entry and exit (proportionate) charges paid by taxpaying trusts, as well as those taxpaying trusts paying ten year anniversary charges. Publishing information on all types of IHT trust charges provides a more complete picture of the activities of taxpaying trusts.
9.3 Commentary on these statistics
Tables 12.7a shows how the net chargeable value of taxable transfers into trusts has remained at around £60 million between the tax years 2009 to 2010 and 2022 to 2023. The net chargeable value of taxable transfers into trusts was particularly high for the tax year 2019 to 2020, with a value of £129 million declared from 40 chargeable events. Despite this, the number of entry charges has remained low, with a total of around 1,200 entry charges paid over the entire period - an average of fewer than 100 per tax year. HMRC collects relatively small amounts in tax from such entry charges - an average of less than £10 million a year over the period.
Table 12.7b and Figure 5 show how the net chargeable value of trusts paying the ten year anniversary charge has increased in recent years to a peak of just under £3.7 billion declared for the 2017 to 2018 tax year. The number of ten year anniversary charges also peaked in that year, at just under 2,000. Since then, the number of trusts and their value has fallen. This could be a consequence of the 2006 trust reforms to tackle tax avoidance using trusts. As part of this package, inheritance tax charges were applied to some types of trust to counter the use of trusts as a means of sheltering wealth. The reduction in assets held in trust may reflect a number of older existing trusts coming to the end of their natural life and a lack of new ones being created. HMRC collects most of total IHT trust charge tax from ten year anniversary charges - with an average total tax liability of around £85 million a year over the period, and a peak of £155 million in respect of the 2017 to 2018 tax year.
Figure 5: Number of chargeable trusts and net chargeable value of assets held in taxpaying trusts, tax year 2009 to 2010 to tax year 2022 to 2023
Table 12.7c shows how the net chargeable value of taxable transfers out of trusts was also high for the 2017 to 2018 tax year, with just over £1.1 billion declared in 2,380 chargeable events. However, the number of exit charges has been falling from a peak of just under 3,000 in the tax year 2014 to 2015. HMRC collects relatively small amounts in tax from such exit (proportionate) charges - an average of around £14 million a year over the period.
9.4 How these statistics differ from other HMRC statistics on trusts
HMRC produces further statistics on trusts. There is a difference in coverage of trusts that pay IHT trust charges and those that face other types of tax charge, as reported in HMRC’s trust statistics publication.
This IHT liabilities statistics publication will include the information of any trusts that face an IHT trust charge as a chargeable event has occurred. It will only include the information of taxpaying trusts. The HMRC trust statistics publication will contain the information of any trusts that submit Self Assessment (SA) returns, regardless of taxpaying status.
For more information on how the coverage of the statistics in this release differs from those in HMRC’s trust statistics, please the coverage section of the background quality report accompanying these statistics.
10. Statistical disclosure control
HMRC uses statistical disclosure control (SDC) to ensure that individuals or groups can’t be identified from statistical data. This means that:
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confidential information about a person or unit (such as a household or business) is not made available; and
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different outputs from the same source, or outputs from different sources, can’t be combined to reveal information about a person or a group of people.
HMRC uses a combination of suppression and rounding for disclosure control. For example, suppression of data, so that the cell value in a table (which may be disclosive where, for instance, the value is small) is not given.
11. Future releases
Next year’s release (scheduled for July 2025) will contain statistics on those estates requiring a grant of representation, together with those estates’ created IHT charges (if applicable), for the tax year 2022 to 2023.