Flexible Reversionary Trust

Setting Up Flexible Reversionary Trust

Thinking of setting up a Flexible Reversionary Trust?

Our estate planning experts can guide you every step of the way from structuring the Flexible Reversionary Trust and choosing the right investment bond to securing long-term inheritance tax benefits. Book a free consultation today.

Reduce Inheritance Tax Without Losing Control

A Flexible Reversionary Trust (FRT) is a highly flexible estate planning tool that helps reduce inheritance tax (IHT) while allowing you to retain access to capital if your circumstances change. One key benefit of using an FRT is its effectiveness for inheritance tax planning, providing both tax advantages and financial advantages for the trust creator and beneficiaries.

Unlike outright gifts, which permanently remove assets from your estate, an FRT strikes a balance between tax efficiency, inheritance tax planning, and financial flexibility.

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    What is a Flexible Reversionary Trust?

    A Flexible Reversionary Trust is a legal structure often used by individuals with larger estates who want to plan ahead for inheritance tax — but aren’t comfortable with giving up control entirely. A client can use an FRT to meet their estate planning needs by retaining access to capital while efficiently managing estate tax liabilities.

    You place a lump sum (usually via an investment bond) into the trust, allowing clients to gift money into the trust. At set maturity dates, you have the option (not obligation) to withdraw funds. If you don’t take them, they remain in trust for your beneficiaries and may fall outside your estate after seven years.

    This makes an FRT a popular solution for people who want to:

    • Reduce the value of their estate for IHT purposes
    • Retain flexibility in case of unforeseen needs
    • Protect beneficiaries by controlling when and how wealth is released
    • Benefit from the flexibility and control that clients require in modern estate planning

    Compared to a discretionary trust, a Flexible Reversionary Trust offers more predictable access to capital and greater control for the settlor, while a discretionary trust gives trustees broader powers over asset distribution.

    The new flexible reversionary trust is an innovative solution for modern estate planning, offering clients adaptable options for inheritance and tax efficiency.

    Offshore Trust

    How Does a Flexible Reversionary Trust Work?

    • You invest a lump sum, typically into an onshore or offshore investment bond, with the Aviva onshore bond being a popular choice for this purpose.
    • The bond is divided into segments with fixed points (fixed maturity dates) (e.g., annually), which are scheduled opportunities for capital payments.
    • At each fixed point, you can receive capital payments by withdrawing the proceeds, or defer payments if you do not need the funds at that time.
    • Deferred capital payments can remain in the trust for future use, allowing access to capital at later maturity dates.
    • The trust structure allows you to receive capital payments at scheduled intervals, providing flexibility to defer or forgo payments as your circumstances change.
    • The initial transfer of assets into the trust is a chargeable lifetime transfer and may be subject to inheritance tax rules and other legal conditions.
    • Trustees oversee the onshore bond and act according to the plan you’ve agreed, ensuring all payments and deferrals are managed appropriately.
    • Over time, funds not withdrawn may fall outside your estate for IHT purposes, and after seven years, the full value of the Aviva onshore bond may be excluded from your estate.

    It’s called “reversionary” because at each maturity, funds could revert to you if you choose — but if you don’t, they continue within the trust as deferred capital payments.

    Interest in Possession Trust

    Why People Use Flexible Reversionary Trusts?

    • IHT Reduction – The initial gift starts the seven-year clock; growth is outside your estate from day one.
    • Control & Flexibility – You retain access at fixed dates, unlike with an outright gift.
    • Protection for Beneficiaries – Distributions can be staggered, preventing mismanagement.
    • Family Wealth Preservation – Capital can be ring-fenced from divorce or creditor claims, ensuring assets are preserved for future generations.
    • Future-Proofing – Useful if you’re unsure about future health or financial needs.

    Flexible Reversionary Trusts (FRTs) help clients achieve their financial goals by allowing for adaptable estate planning that can be tailored to changing circumstances. Compared to loan trusts, which are another popular estate planning tool for inheritance tax planning and allow investment growth to be removed from the estate while offering some capital access, FRTs provide greater flexibility in how and when you can access or distribute assets.

    Discounted Gift Trust

    Tax Benefits of an FRT

    • Seven-Year Rule – After seven years, the gift may fall fully outside your estate, and no inheritance tax is payable on the original capital if the donor survives the full period.
    • Growth Outside Your Estate – Any bond growth is immediately excluded from IHT, and Flexible Reversionary Trusts can be structured to maximize the use of the nil rate band for greater inheritance tax planning efficiency.
    • Withdrawals – If taken, they are usually treated as chargeable gains, not income, which may be advantageous depending on your tax profile. However, any growth withdrawn may be subject to income tax at the beneficiary’s highest marginal rate, and income tax may be payable at the time of withdrawal.
    • Employee Control – If you don’t withdraw, the capital stays in trust, passing to your chosen beneficiaries. The original capital may be tax free upon reversion if certain conditions are met, reinforcing the role of FRTs in inheritance tax planning.

    Pros and Cons of Flexible Reversionary Trusts

    Pros

    • Effective long-term IHT reduction
    • Optional access at fixed maturities
    • Growth excluded from estate immediately
    • Prevents large lump sums going directly to heirs
    • Suitable for staged wealth transfer

    Cons

    • Irreversible once set up
    • Trustees must manage correctly
    • Requires ongoing reviews and planning
    • Withdrawals can create taxable gains
    • More complex than simpler alternatives (e.g., outright gifting)

    Is a Flexible Reversionary Trust Right for You?

    An FRT works best if you:

    • Are in good health and starting IHT planning early
    • Have surplus capital you’re unlikely to need in full
    • Want to reduce IHT exposure without losing flexibility
    • Prefer staged wealth transfer over one-off gifts
    • Are working with an adviser who can manage the trust over time

    As the settlor, you play a key role in establishing and managing the FRT, determining how assets are placed into the trust and how flexible your tax planning can be.

    When considering if an FRT is appropriate, think about potential future needs, such as funding for a residential care home, as this may affect your financial strategy and estate planning.

    Practical Steps

    1. Choose a provider and set up the trust deed.
    2. Invest into an onshore or offshore bond.
    3. Define the maturity schedule (e.g., 10% per year for 10 years).
    4. Appoint trustees and name beneficiaries.
    5. Register with HMRC if required.
    6. Review regularly with your financial adviser to monitor performance and tax.

    It is strongly recommended to seek advice from qualified professionals before setting up a FRT to ensure your decisions are fully informed and tailored to your needs.

    For more detailed information, case studies, and technical resources about Flexible Reversionary Trusts, please contact us.

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    Expert Guidance for High Net Worth Individuals

    1
    Comprehensive Wealth Analysis

    A detailed review of your global assets, liabilities, and family objectives ensures every element of your estate is structured to minimise tax and protect wealth.

    2
    Advanced Tax Mitigation Strategies

    Utilising trusts, Family Investment Companies, and lifetime gifting, we help reduce exposure to Inheritance Tax (IHT), Capital Gains Tax, and other UK and international taxes.

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    3
    Tailored Succession Planning

    Custom plans ensure seamless wealth transfer to the next generation, balancing fairness, family dynamics, and long-term financial security.

    4
    Asset Protection & Risk Management

    Strategies such as Asset Protection Trusts safeguard property and investments from creditors, divorce settlements, and market volatility.

    5
    Global Estate Coordination

    For clients with cross-border assets, we provide integrated planning to manage multi-jurisdictional tax laws and ensure compliance worldwide.

    Frequently Asked Questions

    How does a Flexible Reversionary Trust reduce IHT?

    The initial gift starts the seven-year IHT clock. Growth is outside your estate immediately, and if you survive seven years without withdrawals, the full capital is excluded.

    Yes but only on the maturity dates you’ve chosen. You cannot withdraw funds on demand, which is why HMRC recognises the IHT benefits.

    Typically, investment bonds (onshore or offshore). They’re chosen for long-term growth potential and tax efficiency.

    The original gift may still be counted in your estate, but taper relief applies after year three. Growth remains outside your estate.

    Yes. Any remaining assets stay in trust and are distributed according to your instructions, without being pulled back into your estate.