Cookies are small text files that are stored on your computer when you visit a website. They are mainly used as a way of improving the website functionalities or to provide more advanced statistical data.
Inheritance tax case lost by HMRC; more families could benefit
Newsletter issue – September 2026
HMRC lost a major inheritance tax case, potentially affecting thousands of families who used historic home-loan inheritance planning schemes. The case involved Leslie Elborne's £1.8m home, where her family successfully overturned HMRC's attempt to levy inheritance tax. As a result, her estate avoids an estimated £700k inheritance tax bill.
In 2003, Elborne sold her home to a trust in exchange for a loan note. She then transferred the loan note to another trust for her children. She continued living in the home rent-free. Because she lived more than seven years after the transfer, the loan note fell outside her estate under the rules at the time.
The Court of Appeal ruled that HMRC's anti-avoidance arguments didn't apply, as the scheme pre-dated later rule changes and complied with the law then in force. This ruling sets a significant precedent for families involved in similar legacy home-loan schemes. It may lead to reduced or cancelled inheritance tax liabilities for many long-running disputes.
Book a Free, No Obligation Consultation
Take advantage of a free consultation to see how you can benefit from using Stanhope accountancy and advisory and find out the best way to deal with your tax, accounting and how to minimise your tax liabilities. Book now >
Get a Fixed Quote
We believe you should always be in control of your finances. For this reason we can offer many of our services on a fixed fee basis on agreed services >
Profitability Strategies
We can help you develop strategies to help your business grow without increasing costs specialized tax incentives to produce multiple benefits and help you increase your profit >
Your Business
Expert tax planning advice any size business tailored to you >
