Avoiding the Retirement Tax Trap

21 Aug 25
19 MIN READ TIME

A high net worth guide to investing for retirement; then drawing down tax efficiently

How high‑earning families and business owners can build wealth in anticipation of an early, affluent and tax-efficient retirement.

The retirement tax trap is straightforward: paying more tax than necessary by drawing the wrong money, from the wrong places, at the wrong time. For high net worth households this is could be real money lost every year, compounding across decades and eroding legacies.

This guide is built to be your operational handbook. It explains how to:

  • Map your net-of-tax cashflow and direct funds to the right savings and investment wrappers;
  • Use ISAs, Pensions, GIAs, Onshore/Offshore Bonds and Trusts together – not in isolation;
  • Capitalise on today’s tax allowances and reliefs to invest more tax-efficiently (like the recently increased pension annual allowance of £60,000, and the removal of the Lifetime Allowance charge);
  • Sequence withdrawals to keep taxable income in low bands during retirement (while using allowances efficiently);
  • Plan for the 2027 pension‑IHT reforms to mitigate double taxation;
  • Deploy advanced moves (phased crystallisation, ‘bed & ISA’, bond segmentation) in a compliant and documented manner.

Practical benefit: for many HNW families, re‑sequencing and multi‑wrapper orchestration reduces annual tax leakage by £10k–£30k+ versus a single‑wrapper drawdown, often without reducing disposable income.

The retirement tax landcape at a glance

This section lists the key allowances and rules you will base every decision on, both for saving towards your retirement as well as when eventually drawing down from those investments in retirement.

Key income thresholds and allowances
  • Personal Allowance: £12,570 p.a. per person
    • Protect it! When adjusted gross income exceeds £100k, the Personal Allowance is tapered by £1 for every £2; until it reaches £0 at £125,140 – an effective 62% marginal band when national insurance is factored in on top. Use pension contributions and other forms of salary sacrifice to avoid this cliff.
    • In retirement, use phased withdrawals to keep income-taxable drawdown below £100k each year.
  • Income tax bands (England & NI for 2025/26):
    • 20% basic rate; 40% higher rate; 45% additional rate.
    • In retirement, these determine the marginal cost of pension/ GIA/ bond events: small changes in taxable income can move you across bands with significant tax consequences.
  • Dividend allowance: £500 per person
  • Savings allowance per person:
    • £1,000 (basic rate taxpayer), £500 (higher rate taxpayer), £0 (additional rate taxpayer).

Practical tip: Always start withdrawal planning by listing all taxable sources (rental income; realised gains; dividend income; taxable pension income). Tax bands and allowances should form the ‘frame’ for sequencing.

Capital Gains Tax (CGT)
  • Annual Exempt Amount: £3,000 per person
    • Use it every year – it cannot be carried forward.
  • Rates (recently increased):
    • 18% within basic band;
    • 24% for gains above the basic band.
    • That tightening increases the potential value that can be gained from annual CGT harvesting and ‘bed & ISA’ tactics.

What is ‘bed & ISA’?

  1. Sell the investment outside your ISA
    • You sell your shares, funds, or ETFs held in a general investment account (GIA) or similar.
    • This sale may realise a capital gain — but you can use your annual CGT allowance (£3,000 in 2025/26) to minimise or eliminate any tax liability.
  2. Repurchase the same investment inside the ISA
    • Using the proceeds from the sale, you immediately repurchase the same investment within your ISA (or choose something else entirely).
    • Once inside the ISA, all future growth and dividends are tax-free.

Practical tip: Small, repeated sales in General Investment Accounts – timed to use Annual Exempt Amounts and avoid income band creep – materially beat large once‑off disposals taxed at the higher CGT rate.

Pension allowances and crystallisation rules

Relevant primarily for Defined Contribution (DC) pensions

  • Annual Allowance: £60,000 (or 100% of relevant earnings, whichever is lower).
  • Tapered Annual Allowance:
    • Occurs where threshold income exceeds £200,000 and adjusted income exceeds £260,000
    • Allowance reduces by £1 for every £2 of adjusted income above £260,000, down to a minimum of £10,000.
  • Money Purchase Annual Allowance (MPAA): £10,000
    • Triggered if you take flexible access of your pension; avoid accidental triggers!
  • Tax‑free pension cash/ Lump Sum Allowance (LSA):
    • 25% of the total value of your pensions, capped at £268,275
  • Lump Sum & Death Benefit Allowance (LSDBA): £1,073,100

Practical tip: After the removal of the Lifetime Allowance charge, one blunt cap was replaced with allowances and death‑benefit ceilings. Accessing the tax-free portion of your pension requires careful planning, as phased crystallisation can be more efficient than taking lump sums.

Individual Savings Accounts (ISAs)
  • ISA allowance: £20,000 per person
  • Growth and income on assets held within the ISA are tax free.
  • Withdrawals are tax free and do not count as taxable income – one of the most powerful levers in retirement sequencing.

Practical tip: Use ISAs to hold growth and yield assets that would otherwise generate taxable income in General Investment Accounts (GIAs) or pensions.

Onshore & offshore investment bonds
  • 5% cumulative allowance per policy year: withdrawals up to 5% of initial capital investment (accumulative) are tax‑deferred (not tax‑free).
  • On a later chargeable event, gains are treated as income. ‘Top‑slicing’ relief may reduce the effective tax.
  • Segmentation (issuing multiple small bond segments) enables partial encashments without crystallising the entire bond.

Practical tip: Bonds are sequencing tools – excellent for smoothing when you want to avoid lifting marginal taxable income.

Trusts and their charges

Discretionary trusts carry entry charges, 10‑year periodic charges (up to 6%), and exit charges – all complex, but invaluable where control and estate planning are jointly required with income management.

Practical tip: Use bonds in trust to provide family controlled distributions while preserving beneficiary tax allowances.

The strategic pivot: Pensions & IHT from April 2027

From 6 April 2027, most unspent pensions and many pension death benefits will be included within estates for IHT purposes.

This is a structural change: the once‑automatic IHT shelter provided by pensions will no longer be universally reliable.

Practical tip: Planning that relied on “leaving wealth in pensions forever” should be re‑examined. Sequencing may shift towards partial de‑risking and movement into ISAs/ trusts/ bonds where appropriate.

State Pension

Often overlooked in drawdown, the New State Pension applies to men born on or after 6 April 1951, and women born on or after 6 April 1953.

New State Pension (full rate): £230.25 per week, or about £12,005 per year.

Qualifying years:

  • Minimum 10 years of National Insurance (NI) contributions or credits needed to receive any pension.
  • Full rate requires 35 years of contributions or credits.

Protected payments: If your earnings record from before April 2016 would give you a higher payout under legacy rules, you may receive that as a “protected payment” on top of the current full rate.

Deferral increases entitlement by ~1% every 9 weeks (~5.8% p.a.).

The “triple lock” policy guarantees the New State Pension will rise by the larger of: inflation (CPI), average earnings growth, or 2.5%. In 2025–26, the increase was 4.1%, based on average earnings growth from May-July 2024.

The government has launched the third review of the State Pension age, to determine whether pension age should be automatically linked to life expectancy, possibly raising it even further. The current plan already includes raising the age to 67 by 2027-2028 and to 68 by 2044-2046.

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The orchestration mindset: Principles and objectives

How high net worth households avoid the retirement tax trap.

The objective: Provide for your target net-of-tax lifestyle, sustainably, while minimising total lifetime tax (Income Tax + CGT + IHT) and preserving estate optionality.

Principle 1. Start with spend, not pots

Build a 10- to 30-year plan, that models the net income required each year, stress tested for market downturns and longevity. This should account for irregular outgoings too, such as travel, contributing to school fees, property works, gifting, and care contingencies.

An expert financial adviser will use sophisticated cashflow modelling software that considers a variety of scenarios.

Principle 2. Segment capital by tax behaviour

Define which savings and investment pots are tax‑free, tax‑deferred, taxable and trust/ legacy oriented.

  • Tax-free: ISA
  • Tax-deferred: Pensions & Bonds
  • Taxable but manageable: GIA
  • Plus, those which are Trust-based to offer control & IHT shaping
Principle 3. Sequence withdrawals to preserve low-rate bands
  • Use allowance‑rich pots first and leave taxable pots to years where other income is low;
  • Keep taxable income inside lower bands/allowances;
  • Harvest CGT each year without eroding core capital;
  • Maintain optionality for later-life and estate outcomes.
Principle 4. Split ownership of assets

Share key allowances between spouses;

  • Personal Allowance
  • CGT Annual Exemptions
  • Dividend allowances

…to avoid higher tax bands as individuals.

Principle 5. Preserve optionality

Avoid locking all capital into illiquid or high-penalty structures.

For example, pensions generally cannot be accessed until age 55 (rising to age 57 in 2028), and now face potential double taxation inside estates for IHT purposes.

Principle 6. Annual discipline
  • Harvest allowances;
  • Move assets to ISAs when appropriate;
  • Re-sequence if income profile changes;
  • Crystallise gains;
  • Reset bond segments; and
  • Top up a 2-3 year cash bucket so markets don’t dictate tax timing.

Tax optimisation is allocation and timing: Think allocation (ISA vs GIA vs pension) and timing (year to year sequencing). For HNW households, a modest shift in timing often outperforms a risky, concentrated tax shelter.

Total-return beats income-only: Preferring high yields traps you in dividend tax bands and concentration risk. A total-return approach with controlled sales from the optimal wrapper gives cleaner tax and risk management.

Wrapper-by-wrapper: Deep dive and pro moves

What each wrapper really does, and how to use them. These are the rules, tactical moves, common pitfalls and pro plays for each wrapper.

Pensions – the orchestration core

Core rules:

  • Up to 25% tax-free, but limited by LSA £268,275 (protections aside). Remainder taxed at your marginal rates.
  • Contributions: Annual Allowance £60k, taper from £260k adjusted income (min £10k). MPAA £10k if flexibly accessed.
  • Flexi-access drawdown vs UFPLS: both create taxable income beyond the tax-free element; beware Emergency (Month-1) tax on first payments; reclaim via P55/ P53Z/ P50Z.

What they do well:

  • Tax relief on contributions;
  • Tax‑deferred compounding;
  • Structured death benefits (beneficiary rules).

Key constraints:

  • Taxable on withdrawal beyond PCLS/ LSA;
  • MPAA may restrict future contributions once flexible access is used;
  • PCLS subject to LSA cap;
  • 2027 IHT inclusion looms.

Pro moves:

  • Earning between £100–£125k? Combine pension contributions and other salary sacrifice to reclaim or preserve Personal Allowance (effective 62% marginal relief zone).
  • Phased crystallisation:
    • Crystallise small portions each year to realise up to 25% tax‑free cash (within LSA) and keep taxable income inside target bands.
    • Preferred to large UFPLS where MPAA or rate spikes may occur.
  • PCLS-only first draws (where legally feasible) to avoid MPAA trigger in the short term. Document carefully.
  • Pension contributions as tax-band management: for those near the PA taper band, an extra pension contribution or Gift Aid top‑up can reduce adjusted net income, restoring PA or reducing marginal rates. (Use with caution and model liquidity.)

Common mistakes:

  • Emergency tax shock on first draw; plan cash and reclaim promptly.
  • Taking a large UFPLS early, triggering MPAA or pushing into 45% band. Can trigger HICBC/ benefit cliffs for under-retirement-age households.
  • Failing to segment crystallisations, losing LSA advantage or incurring unnecessary income spikes.
ISAs – the retirement workhorse

Core rules:

  • Withdrawals are tax-free and don’t count as income for tax-band tests – ideal for smoothing income and avoiding higher-rate thresholds.
  • £20,000 p.a. use-it-or-lose-it allowance per person.

What they do well:

  • Tax‑free withdrawals;
  • Tax-free growth and income on investments within ISAs;
  • Do not count as taxable income;
  • Ideal for smoothing tax bands.

Pro moves:

  • Prioritise funding ISAs in accumulation years after covering tax‑efficient pension contribution needs.
  • Family pooling: two spouses = £40k p.a.
  • Bed & ISA‘ GIA assets each year to migrate yield/ growth into a tax-free silo.
  • Park high-yield or fast-growing assets inside ISA to silence tax drag.

Common mistakes:

  • Putting low‑growth or defensive assets into ISAs, while leaving high‑growth investments in pensions/GIA – match asset to wrapper strategically.
GIAs – taxable but flexible

Purpose:

Flexible, taxable accounts used for CGT harvesting, dividend management and bridging between tax‑sheltered pots.

Pro moves:

  • Annual CGT harvesting: Crystallise up to £3,000 p.p. every year. Split across spouses for double allowance.
  • Bed & spouse’ transfers: Shift gains to the spouse with lower rates or unused allowances (watch out for 30‑day/ share-matching rules to avoid wash sales).
  • Prefer funds with accumulation units where dividend stuffing would otherwise create tax drag.
  • Target dividends within the £500 allowance; progressively migrate surplus yield into ISAs.
Onshore & offshore investment bonds – mastering deferral

Purpose:

  • Create tax-deferred cashflow via the 5% cumulative allowance – useful when you want spending power without lifting taxable income;
  • Top-slicing relief may mitigate a large one-off encashment if held many years;
  • Assignments (to spouse/trust) normally no gain/ no loss – can shift future gains to different taxpayers/structures;
  • Useful in early retirement or when deterministic withdrawals are required.

Design tips:

  • Segment policies at outset (e.g., 10–100 segments) to allow partial encashment without crystallising the whole bond;
  • Match bond type to tax profile: onshore has a basic-rate credit; offshore maximises gross roll-up but gains are fully income-taxed when they arise.

Pro moves:

  • Segment large bonds into multiple policies/ segments to allow partial surrenders;
  • Use top‑slicing relief modelling when planning a large encashment;
  • Assign to spouse or trust as part of intergenerational planning (assignment usually non‑taxable).

Common errors:

  • Treating 5% as tax-free (it’s deferred); always model the eventual chargeable event with future expected income bands;
  • Large future chargeable events can collide with high-rate bands or Personal Allowance taper.
Trusts – for control

Purpose:

  • Control, protection, and IHT management for surplus capital;
  • Ring‑fencing and bespoke distributions;
  • Useful when a retiree wishes to provide controlled family income without inflating personal taxable income.

Key charges:

  • Entry: ~20% on value above available Nil-Rate Band (NRB) for discretionary trusts;
  • Periodic (10-year) charge: up to 6% above NRB;
  • Exit charges apply on capital appointments.

Where Trusts meet retirement income:

  • House surplus capital in trust (often using bonds) to deliver trustee-controlled distributions while ring-fencing from your personal bands/ means-tests.
  • Time trustee distributions around beneficiaries’ allowances (e.g., adult children in low bands).

Pro move:

  • Use trusts for pension death benefit holding where legislation permits (but seek legal advice).

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Withdrawal sequencing playbook

Concrete algorithms and templates you can run each year, according to your household’s objectives.

An expert financial adviser will revisit your sequencing strategies each year using cashflow modelling; taking into account market fluctuations, tax allowances and reliefs, and your changing tax bands.

Template A: Keep taxable income ≤ basic-rate band
  1. ISAs first (withdraw tax‑free cash to meet most of the need).
  2. Bond 5% allowances next (tax deferred).
  3. GIA disposals up to CGT Annual Exemption.
  4. Pension taxable draw only to fill remaining PA/ basic band headroom.

This maximises tax‑free draw, defers taxable draws until necessary, and avoids creeping into 40/ 45% income tax territory.

Template B: Materially zero-tax year
  1. ISAs first;
  2. Bond 5% allowances next (tax deferred);
  3. Pension up to Personal Allowance only;
  4. Harvest CGT Annual Exemption in GIA, but avoid creating dividend income beyond the £500 allowance.
Template C: Estate-centric pre-2027 reposition

Goal: Re‑weight pension‑heavy estates to reduce 2027 IHT exposure, without spiking marginal tax rates.

  1. Cash & ISA top ups;
  2. Phased crystallisation of smaller pension tranches to preserve PA and basic rate (not UFPLS lumps) to re-weight gradually from pension to ISA/ bond/ trust;
  3. GIA to fund bed & ISA over multiples years;
  4. Onshore bond assignment to trust where continuity of control is needed;
  5. Life cover in trust to insure IHT if immediate migration impossible.Note: model run‑rate impact carefully; acting too quickly may crystallise gains or incur large income tax;
  6. Maintain a cash buffer (2–3 years) to avoid forced selling in down markets, preserving tax control into 2027+.

Important: Your financial adviser shoudl model the run‑rate impact carefully; acting too quickly may crystallise gains or incur large income tax.

Implemetation algorithm (annual):

  1. Forecast the next 24 months of required net spending (base and irregular);
  2. Project all expected non‑portfolio income (state pension, rental, interest);
  3. Run the sequencing template to meet net spend, while keeping taxable income within parameters;
  4. Update ISA/ CGT harvest/ segment bond decisions for each tax year;
  5. Rebalance, migrate high‑return assets into ISAs if room, and reset bond segments.

Example case studies

These examples show the numerical effect of sequencing. All examples are simplified and illustrative. An expert financial adviser can show more precise outcomes through cashflow modelling. Investment risk, sequencing, spend patterns and wrapper history will alter outcomes.

Example A: £80,000 lifestyle with minimal/ zero tax

Two spouses age 60 and 58 target £80,000 annual expenditure.

Asset breakdown:

  • Pensions: £900k (uncrystallised)
  • ISAs: £450k
  • GIAs: £500k
  • Offshore bond: £300k (10 segments)
  • Cash: £50k

Annual drawdown plan (year 1):

  • Withdraw £40,000 from ISAs (untaxed)
  • Withdraw £15,000 from offshore bond (5% allowance of £300k, tax deferred)
  • Each crystallise pension income equal to Personal Allowance of £12,570, using PCLS to fund the tax‑free portion (zero taxable income)
  • Realise £6,000 in gains from GIA (utilising annual exemption)
  • Earn dividends up to £1,000 (utilising allowances); migrating high-yield positions into ISAs over time.

Net result:

~£80k cash flow with negligible/ zero current-year income tax; no CGT; bond withdrawals deferred; pensions largely untouched and compounding.

Why it works:

Layering tax‑free and tax‑deferred withdrawals plus spouse allowances to avoid higher bands.

Example B: £1m pension single drawdown (hidden leakage)

Single age 62 targets £80,000 gross from their pension alone.

Income tax:

  • First £12,570 at 0%;
  • Next slice at 20%;
  • Next slide at 40%
  • Typical tax bill £20k-£25k+ p.a. (exact amount depends on other income).

At this rate the pension could run out entirely in less than 20 years, assuming 5% net growth. A quarter of the pension pot is lost unnecessarily to income tax.

This is avoidable if part-funded from ISA/ bond/ GIA to cap marginal rates and preserve allowances.

Example C: £1m portfolio capping lifetime tax exposure

Asset breakdown:

  • Pensions: £450k
  • ISAs: £250k
  • GIAs: £200k
  • Onshore bond: £100k

Strategy:

  • Years 1-5:
    • Withdraw from ISA (tax free);
    • Withdraw £5,000 from onshore bond each year (5% allowance of £100k, tax deferred)
    • Crystallise pension income equal to Personal Allowance of £12,570 each year
    • Harvest £3k CGT (within annual exemption) via GIA each year
  • Years 6-10:
    • Phase pension crystallisations to keep within basic rate band (20%), avoiding higher income tax rates where possible;
    • Make gifts from surplus income
  • Estate planning considerations:
    • Review pension nominations and possible bypass/ discretionary trust strategies for death benefits;
    • Consider writing a life cover plan in trust to meet an eventual IHT liability;
    • Gradually re-weight across wrappers.

Outcome:

Materially lower lifetime income tax and lower projected IHT exposure vs a pension-only draw.

Example D: Significant one-off cash is needed (e.g. renovation)

Strategy:

  • Split across two or more tax years if possible;
  • Use ISA first;
  • Use bond encashment with top-slicing analysis (consider partial segment surrenders);
  • Pension: crystallise tranches to maximise PCLS and keep taxable slice within target bands;
  • GIA: realise gains up to CGT annual exemptions across both spouses.

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Advanced strategies for HNW households

Phased crystallisation with PCLS routing

Crystallising small pension tranches each year (taking tax‑free element where available, and only taxable as needed) reduces marginal tax spikes and preserves MPAA headroom. Document precisely for HMRC (dates, amounts).

Bond segmentation and top-slicing

Issue multiple small bond segments (or purchase multiple small policies) to aid partial surrenders and preserve the 5% allowance across different policy anniversaries. When a larger encashment is required, estimate top‑slicing relief to reduce the effective tax rate.

Trustee distribution engineering

Trustees can smooth distributions to beneficiaries so the household uses beneficiaries’ PA and lower bands, preserving the settlor’s tax bands and potentially keeping the settlor’s taxable income low (subject to trust tax rules).

A measured approach to lifetime gifting

Where wealth exceeds long‑term needs and IHT is a concern, measured regular gifting (within the normal expenditure out of income rules) can reduce estate exposure without incurring IHT charges. Keep precise records – to prove regularity to HMRC.

Your tax trap checklist

Before your first withdrawal

  • Decide on draw type (phased PCLS and income vs UFPLS).
  • Avoid MPAA trigger unless unavoidable.
  • Confirm tax code to avoid Emergency (Month-1) tax shock.
  • Factor in other income (rent/dividends) to avoid band creep.
  • Coordinate spouse allowances (PA/ Dividend/ CGT).

Annual actions

  • Max usage of ISA allowance (£20k p.p.).
  • Harvest Capital Gains up to annual exemption (£3k p.p.).
  • Review dividend flows vs £500 p.p. allowance.
  • Rebalance risk and refill cash reserves.

Estate planning factors

  • Model 2027 pension-IHT exposure; review death-benefit nominations and potential trust structures.
  • Review Wills/ LPAs; keep pension expressions of wishes current.
  • Consider a life plan in trust to meet anticipated IHT liability.
  • Keep robust gift records (rules may change over time).

Integration with portfolio design

  • Total-return orientation with factor & geographic diversification;
  • Asset location (what sits where):
    • ISA: growth and high-yielding assets;
    • Pension: equities for long runway (tax-sheltered compounding);
    • GIA: tax-efficient funds/ETFs; prefer accumulation units only when they don’t create dividend tax drag beyond allowance;
    • Bond: lower-volatility sleeves to stabilise 5% withdrawals.
  • Rebalancing: set hard ranges; use flows to minimise CGT.
  • Costs: consolidate legacy plans where sensible; monitor ongoing charges and platform fees.

DIY vs Professionally Advised: The Drawdown Pay-Off

When entering retirement, the decisions you make around how, when, and from where you draw your income can add – or subtract – hundreds of thousands of pounds from your future wealth.

Retirees who ‘go it alone’ often underperform – not because of poor investment returns, but because of suboptimal drawdown sequencing and missed opportunities.

Apollo Private Wealth orchestrates every moving part: income sourcing, wrapper sequencing, tax harvesting, inflation protection, and estate planning – producing materially better financial outcomes over the long term.

The four biggest DIY mistakes

Front-loading pensions

The problem:

Many DIY investors take the majority of income from pensions first, triggering unnecessary income tax at 40%+ and eroding future compounding potential.

Apollo’s advantage:

Apollo blends ISAs, GIAs, pensions, and bonds intelligently to minimise tax drag and maximise portfolio longevity.

Overlooking allowance stacking

The problem:

DIY retirees often underuse the CGT annual exemption, dividend allowance, and personal savings allowance – meaning they overpay HMRC every year.

Apollo’s advantage:

Apollo engineers an “allowance-maxing” waterfall that uses every relief available. Typical saving: £7,500-£12,000 per year.

Sequence-of-returns risk

The problem:

Withdrawing from growth assets after a market crash can lock in permanent losses – a risk many DIY retirees are blind to.

Apollo’s advantage:

Apollo applies buffer strategies and dynamically switches wrappers to protect growth assets until recovery.

Underestimating longevity

The problem:

Many retirees overspend in the early years or fail to inflation-proof later spending, risking depletion. Assets are eroded quickly by unnecessary taxation, rather than continuing to compound.

Apollo’s advantage:

Apollo stress-tests against 100+ scenarios (inflation spikes, recessions, policy changes) to maintain sustainable drawdowns.

How we add value to every £1 withdrawn:

Tax Alpha → Saving £100,000s+ over decades

Behavioural Alpha → Avoid panic-selling, stick to plan

Sequencing Alpha → Reducing portfolio depletion risk

Legacy Alpha → Integrated estate strategy more wealth passed on to your beneficiaries

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The art of retirement drawdown isn’t picking a single ‘best’ pot. It’s orchestrating all of your pots – year by year – to spend well, stay in low bands, and keep options open as rules evolve (not least the 2027 pension-IHT shift). Get the sequencing right, and you keep more of your money – every year for the rest of your life.

SJP Approved xx/xx/xxxx

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