Mike Pugh, founder of MP Estate Planning. “Presto magic, there’s no tax.”

MP Estate Planning: the unregulated firm selling defective trusts to the elderly

March 13, 2026

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MP Estate Planning is an unregulated advisory firm using an extensive social media campaign to sell expensive “asset protection trusts” to elderly homeowners, often of relatively modest means.

The pitch is simple: put your home into a trust and you can avoid inheritance tax, care home fees, divorce claims and creditors. Our investigation, drawing on the expertise of over a dozen specialist lawyers and tax advisers, found that the claims are false – and may leave families facing large tax bills and, ultimately, cause a complex and expensive probate process.

We were disappointed but not surprised to find trusts being missold – that’s been going on for years. What we found was much worse – a firm that operates on the edge of legality, and may step over the line. A series of misrepresentations as to what it is and what it does, and advice to clients that goes beyond “merely wrong” into shocking negligence. And when we asked MP Estate Planning for comment, they failed to provide any response to our technical criticisms, and provided answers to other points that we consider to have been intentionally misleading.

The length of this report reflects the seriousness of what our investigation found.

The problems with MP Estate Planning

It all starts with a lack of expertise. The firm’s founder, Mike Pugh, says he is an “estate planning lawyer”. He isn’t. The firm’s website says it employs “experienced lawyers”. That is also untrue. We believe nobody at MP Estate Planning has any legal, tax or accounting qualifications.

The lack of expertise doesn’t stop the firm marketing its business very aggressively. It has over 400 videos on social media pushing an alarmist message: “if you own anything, it can be taken from you”. Pugh says their mission is “quite literally to save the middle class from being completely wiped out in the UK”. The solution is simple: “every home in a trust” – and they’re pushing this proposition to elderly people with assets of as little as £150,000:

The firm’s videos and website make a variety of striking claims:

  • You put your house and other assets in trust. They’re then outside your estate for inheritance tax purposes.
  • There are no adverse tax consequences of this.
  • The trust will reduce probate costs.
  • Your house won’t be assessed in determining whether you have to contribute towards care home fees (should they be needed).
  • You can financially support your children after you die, but if they divorce then their spouse will have no claim on their assets.
  • Assets in the trust are safe from your creditors, and can’t be touched if you go bankrupt.

All these claims are false. The Society of Will Writers has published guidance telling its members not to make these kinds of claims.

Our investigation uncovered multiple serious problems with MP Estate Planning’s claims and business practices.

  • Lifetime trusts are poor tax planning for most people. They often result in more inheritance tax because the spouse exemption and residence nil rate bands aren’t available to trusts.
  • The MP Estate Planning structures we reviewed have no material tax benefit and likely trigger a series of unnecessary tax bills.
  • One experienced adviser told us that the tax claims made by MP Estate Planning were so egregiously bad that they looked like fraud (although most of our team believe the firm is just unqualified and reckless).
  • They publish hundreds of videos which include multiple legal errors, often referring to US law concepts that have no equivalent in the UK. Their website is full of false claims and appears to be largely AI generated.
  • The firm claims the backing of an eminent KC, James Kessler, who told us he’s never given it, and in fact told MP Estate Planning to stop using his name.
  • MP Estate Planning claim their “head of legal”, and Mike Pugh’s mentor, is Dr Paul Hutchinson, who “trained with Kessler for 20 years”. In fact MP Estate Planning have never had a “head of legal”, or indeed any legally qualified staff at all. Dr Hutchinson told us he has never met Mr Kessler, and has never had any dealings with MP Estate Planning.
  • It appears that the firm is drafting property trusts for its clients, despite not employing qualified lawyers. If so, that’s potentially a criminal offence. And we’ve seen trust deeds that include very basic but highly significant errors.
  • Mike Pugh’s previous firm, Maplebrook Wills Ltd, went bust owing £1.7m to HMRC – an extraordinarily large amount for a small will-writing business. Mike Pugh’s actions are currently being investigated by the company’s liquidator.

We therefore believe MP Estate Planning is misselling trusts to people who probably do not need them and who are unprepared for the legal and tax complexities these structures create. Bad inheritance tax planning usually remains hidden until the taxpayer dies, decades after the planning was put in place. It is the taxpayer’s grieving children who are then left to pick up the pieces.

A prominent Scottish law firm failed in 2021 after selling unsuitable “family protection trusts”. Its pitch was similar to MP Estate Planning – but at least it was regulated, and so its clients had the prospect of recovering their loss. MP Estate Planning is completely unregulated, and anyone let down by its trusts will have no recourse at all.

We will be referring the firm to the Solicitors Regulation Authority for carrying on reserved legal activities without authorisation. We hope that HMRC investigates the firm for failing to disclose tax avoidance schemes.

Technical terms in this article
Trust
A legal arrangement where the legal ownership of assets (held by trustees) is separated from the beneficial ownership (those entitled to benefit).
Trustee
The person (or company) holding legal title to trust assets. They must manage the trust according to the trust deed and the law.
Bare trust
A simple trust where the beneficiary has an immediate and absolute right to both the capital and income of the trust.
Discretionary trust
A trust where the trustees have the power to decide how and when to distribute income or capital among a defined group of beneficiaries.
Settlor-interested trust
A trust where the settlor (or their spouse/civil partner) can still benefit from the trust assets. This has major tax implications, such as the denial of certain tax reliefs.
Gift with reservation of benefit (GWROB)
An anti-avoidance rule where someone gives away an asset but continues to benefit from it (like giving away a house but still living in it). For inheritance tax purposes, the asset remains in their estate.
Anniversary charge / 10-year charge
A periodic inheritance tax charge of up to 6% applied to the value of relevant property trusts (like discretionary trusts) every 10 years.
Capital Gains Tax (CGT)
A tax on the profit when you sell or dispose of an asset that has increased in value. Transfers into trusts often count as a disposal for CGT purposes.
Hold-over relief
A tax relief that allows the deferral of Capital Gains Tax when giving away certain assets (like business assets or transfers into trusts), passing the potential tax liability to the recipient.
Deliberate deprivation of assets
When someone intentionally reduces their assets (e.g., by putting a house in a trust) to qualify for state-funded social care. Local authorities can assess them as if they still owned the assets.
DOTAS (Disclosure of Tax Avoidance Schemes)
Rules requiring promoters of certain tax avoidance schemes to disclose them to HMRC, giving HMRC early warning of avoidance strategies.

The red flags

Before we present the products sold by MP Estate Planning, and the reasons why they don’t work, there are numerous red flags that in our opinion indicate this is not a business to be trusted.

Deceptive claims about their expertise

Mike Pugh says he’s an “estate planning lawyer”:

He isn’t. Mike Pugh worked as a Will writer after emigrating from Canada to the UK. He set up MP Estate Planning in 2023, but has no UK legal, tax or accounting qualifications. It’s an offence to hold yourself out as a solicitor or barrister, but the term “lawyer” is not legally protected. We nevertheless regard it as highly misleading for someone with no legal qualifications to claim to be a lawyer.

The MP Estate Planning website said they are a firm of “experienced lawyers” – this is untrue. We can’t identify anyone at MP Estate Planning who has any legal, tax or accounting qualifications. Neither any of the staff nor the firm itself is regulated. When we asked MP Estate Planning about this we didn’t get a response; they just changed the website.

Here’s the, fairly typical, CV of one of their representatives: he worked in sales until nine months ago, and now claims to be an “estate planning consultant” who can “specialise in delivering advanced, compliant and highly tailored estate planning solutions”:

Experience

Estate Planning Consultant

a MP Estate Planning UK - Self-employed
Jan 2025 - Present - 1 yr 3 mos
Remote

As an Estate Planning Consultant at MP Estate Planning, | specialise in delivering advanced, compliant, and
highly tailored estate planning solutions for individuals and families across the UK. My role... more

9 Technical Knowledge of Trusts & Tax Law, Client-Focused Communication and +3 skills

Head of sales and partnerships
| Emerse marketing
Jul 2025

Regional Sales Associate
B Bionic - Full-time
Jan 2024 - Jul 2025-1 yr 7 mos
North Yorkshire, England, United Kingdom - Hybrid

In reality he’s still working in sales, just with a different job title.

We can see how MP Estate Planning hires and trains its salespeople from a recent recruitment advertisement:

It takes three to five years to train to be a chartered accountant and two years to train to be a chartered tax adviser. MP Estate Planning tell their salespeople they can earn £20,000 per month after three weeks’ training. That would be less concerning if all they did was sales; but they tell potential clients they’re “consultants”, and we’ve seen multiple cases where the salespeople claim to be qualified to give advice.

Nobody else involved appears to have any relevant qualifications. Dan Irwin, MP Estate Planning’s “head of property” was previously a director of Safe Hands Plans Ltd, a pre-paid funeral plan business which collapsed in 2022, with 46,000 people losing most of their money. Two individuals who ran the business are currently being prosecuted for fraud. There is no suggestion Mr Irwin was involved in the fraud, and we don’t know if the fraud was underway when Mr Irwin ceased to be a director in April 2018.

The website says they work with a solicitors firm called Feakes & Co – but the firm told us that, whilst they provide some “corporate advice” to MP Estate Planning, their role “does not include designing or drafting trust structures or other such documents for them or their clients”.

MP Estate Planning told us that “Where a client’s circumstances require specialist or regulated advice, we refer or signpost to appropriately qualified external professionals”. However, there’s no sign that the trust deeds we reviewed were drafted by an external firm – the only firm mentioned on them is Feakes & Co, apparently because they undertake trust registrations.

Mike Pugh describes his “head of legal” in numerous videos. There isn’t one. MP Estate Planning has never had a lawyer on its team:

We asked Pugh about this. He responded:

“You raise the point about references in video material to a “head of legal”. This refers to the involvement of legally trained professionals within the wider advisory ecosystem we work with, rather than suggesting a formal internal role that does not exist.”

That is a very unconvincing explanation of what we would characterise as a lie.

Mike Pugh often claims an association with James Kessler KC, often rated as one of the country’s leading private client advisers, and Dr Paul Hutchinson🔒, a respected Will writer (with a PhD in Law), who appears to be the man he’s saying is his (non-existent) “head of legal”:

First video: “We use the Kessler 15th edition, James Kessler KC. I’ve actually had emails with him allowing me to use the precedents. He’s a lovely man. He’s the number one guy for taxes and trusts worldwide, period. I’ll just throw a shout out to my mentor, Dr. Paul Hutchinson, who I’ve worked closely with for 10 years. Paul trained under Kessler for 20 years. So we’re pretty comfortable with our technical capabilities.”

Second video: “At MP Estate Planning UK, our head of legal is a doctor of law specialising in taxes and trusts.”

Mr Kessler is the lead author of a well known practitioners’ textbook on Wills and trusts, which includes trust and Will precedents. He has never met Dr Hutchinson, much less trained him for 20 years. The claim that MP Estate Planning had some kind of special permission to use the precedents is false – and that plus other uses of his name🔒 sufficiently alarmed Mr Kessler that he includes a warning on his website:

MP Estate Planning (UK)

This company have been marketing themselves as Kessler Will UK and as providing “Kessler Wills”. This has been done without James’ permission.

James has no association with this company. He does not endorse this company or any of their so-called “Kessler Wills”. He does not vouch for any product offered by this company.

On 10 November 2025 the company has, through its directors, entered into formal undertakings including not to use or refer to the name Kessler and/or to use or refer to “Kessler Wills”.

If anyone is aware of them using the name Kessler or the phrase “Kessler Will”, or holding themselves out as being associated or endorsed by James, please let us know at the email address on this website

In all cases, James strongly recommends you take advice only from solicitors or accountants who are qualified and regulated.

Dr Hutchinson told us he used to provide in-house training for Pugh’s previous firm Maplebrook Wills. He lent the firm some money, and became a shareholder to try to recover it – but then Maplebrook Wills went bust and he was never repaid. He says he’s had nothing to do with Mr Pugh since:

I wish to have no association with Mr Pugh or his company and do not consider myself his mentor… for the record I have never met Mr Kessler let alone “trained under him”. I have his texts as reference material, but that is it.”

We can’t find any evidence that MP Estate Planning has a “head of legal”, but it certainly isn’t Dr Hutchinson.

MP Estate Planning continued pushing out marketing containing falsehoods even when they knew this report was about to be released. This was sent to their mailing list the day before we published:

Every senior politician does not have a trust. Trusts are poor tax planning for most people. So it is therefore unsurprising that the List of Ministers’ Interests and the Register of Members’ Interests show only a small number of politicians declaring family trusts. We cannot know for sure, but we are very sceptical that MP Estate Planning has any senior politician as a client.

These claims – particularly the “head of legal” and “trained under Kessler for 20 years” were more than slips of the tongue, or the typical exaggeration of a salesman. They were concrete claims, made repeatedly. Mr Pugh surely knew the claims were was false. It is not far-fetched to suggest that a criminal offence may have been committed here.

A deceptive website

The MP Estate Planning website has several elements we regard as deceptive.

First, the claimed associations and awards are untrue and misleading.

fo y
[L-ONN
New Leaf )

Top Will Writer 2014,2016,2017

With more than a decade
of experience, Michael

expert in client care.
YouTube has multiple
videos from clients’
children - grateful for the
advice.

Legal

Working In Conjunction With:

BEST
Pill

Directorate assists

clients in finding reliable
Pugh is an award-winning top-tier firms that cater to

the

ir specific needs,

whether for tax preparation
services or representation

in intricate legal

proceedings.

chartered
nsurance
2% Institute

Standards. Professior alism. “rust

Feakes & Co icO
e

Information Commissioner's Office

The Information
Commissioner's Office
(ICO) is a non-
departmental public body
which reports directly to
the Parliament of the
United Kingdom and is
sponsored by the
Department for Science,
Innovation and Technology.

Feakes & Co Ltd are
authorised and regulated
by the Solicitors Regulation
Authority (SRA) number
654837, and registered in
England and Wales with
company number 11514461

The Chartered Insurance
Institute (Cll) is a
professional body
dedicated to building
public trust in the insurance
and financial planning
profession.

We spoke to the Chartered Insurance Institute. They’ve never heard of Mike Pugh or MP Estate Planning, and neither are members of (or have any association) with the Chartered Insurance Institute.

Pugh told us:

Some of our colleagues are members or graduates of the Chartered Insurance Institute include Mr Zubair Abad.

There is no formal relationship with the Institute itself. We have amended the wording on our website to more accurately reflect this.

Zubair Abad does not appear to be a member of the CII. It is possible he has CII qualifications. The wording on the website now says MP Estate Planning is “Aligned with or members of” the CII and other organisations. That still seems to us to be misleading.

Second, the claimed award from “Legal Directorate” was phony. Legal Directorate is a “pay for play” directory which uses AI to generate fake reviews and fake awards, with listings of “best firms” that (with respect to the firms listed) are not credible:

LEGAL V /
| DIRECTORATE London Q 

| Business and Tax Advisors
Kkkkh

Sole Traders

“| like their flexible approach. | had a bunch of

small problems what was too little to big firms but
too big for me. They explained the process, fees
etc and solved my troubles. Price wise also been
on the better side. Personally | recommend...”

| View Profile |

* Family Business ¢ Transparent Fees & Pricing
a Remote Consultations ig Free Initial Consultation
Available

fF Accountants

kekekk | View Profile |

(Internal Auditing, MTD, CIS

TER 3 ccountants is a very competitive firm,

and Mr Adil is more a friend than an accountant to
all his clients. His assistance for my tax returns is
always adequate, and he never lets me leave
without a cup of coffee. :) Positive
Professionalism”

© 12+ Years Experience Coupons & Offers

Serving London Area

At some point someone paid for an entry/award for Mike Pugh’s old firm, Maplebrook Wills. When he set up MP Estate Planning Ltd, it “inherited” the fake award, but Legal Directorate never changed the url – it’s still “https://legaldirectorate.co.uk/company/maplebrook-wills-441174401555-weston-super-mare/“, with reviews that are likely fake/AI generated.

Since we asked about this, the “Legal Directorate” badge disappeared from the MP Estate Planning website.

Poor understanding of English law and UK tax

The MP Estate Planning videos and websites show a very limited understanding of UK tax and the English law of trusts. Here’s Mike Pugh last month:

“Never transfer your assets into your kids’ names, especially real estate. Here’s why.

Let’s say you bought a home many years ago for £300,000, and now it’s worth £900,000.

If you transfer or dispose of the property, you could trigger a capital gains charge, and your children might be responsible for paying a charge on the £600,000 of gain.

There are workarounds. For example, if your children move in and live with you, then you may be able to transfer the property to them without triggering the capital gains tax, as long as you continue to qualify for the main residence relief or private residence relief.

An easier solution than living together is to set up a trust and put your house into the trust and name your adult children as trustees and beneficiaries.

If you want to protect your home and see it safely get to your kids, click on the link in the description to watch my free master class on how to put assets into trust in the UK.”

This is nonsense from start to finish. If it’s your home, then the main residence exemption usually applies – so there’s no capital gains tax if you give the property to your kids. If it wasn’t your main residence then there would be CGT, but on you and not your kids. Having the children live with you wouldn’t change the result in any way.

When we wrote to MP Estate Planning for comment in advance of publication (see below), their explanation for this video was that “the editing of the short-form clip conveyed the point poorly and could lead to confusion”. This is not credible. The statements above are complete propositions expressed in full sentences; they are not the product of an ambiguous or misleading edit. We put this to Mr Pugh; we didn’t receive a response.

It is hard to see any explanation for this video other than that Mr Pugh had no understanding of basic UK tax principles.

A series of errors

There are other basic errors and false claims in the many videos published by MP Estate Planning.

A video on cryptocurrency claims “certain reforms by the Labour Party may lead to increased tax guidelines on digital assets. This could impact how they are taxed during transfers and inheritances” – but there are no planned or announced changes to the UK tax treatment of cryptocurrency.

Another video says that if you declare a bare trust then the assets are still considered part of your estate and your estate pays tax on the income. That’s false: the beneficiary of a bare trust is usually considered the owner, and pays tax on the income.

And in another video, Mike Pugh says there’s stamp duty if parents gift their home to their children – there isn’t.

There are lots of small errors like this that we regard as “tells” – signs that Pugh and his colleagues don’t understand their subject. Then there are some very large errors – the firm seems to believe that English law is similar to US law, when it very much is not.

Confusion between UK tax and US tax

Mike Pugh frequently talks about “revocable trusts” and “irrevocable trusts”. These are US tax terms, which no competent UK adviser would use:

This isn’t a one-off. Multiple videos on MP Estate Planning’s YouTube channel, and dozens of pages on their website, discuss revocable and irrevocable trusts. In this video, Pugh claims that revocable trusts avoid probate and are “commonly used in estate planning”. They do not and they are not. Indeed American citizens who move to the UK are usually advised to terminate revocable trusts, because of the uncertainty as to how the UK system characterises them:

In this video, Pugh says that “revocable and irrevocable is more to do with tax status” and that you can “close” an irrevocable trust with an “advancement of the trust period”. None of this has any meaning in English law.

And this, from “frequently asked questions” on the MP Estate Planning website, suggests the firm is actually setting up “revocable trusts” for their clients:

Can I make changes to my trust after it’s set up? a

Yes, if you set up a revocable trust, you can make changes, add or remove beneficiaries, and amend terms during your lifetime. However, irrevocable trusts are more difficult to change,

offering more asset protection but less flexibility.

We asked MP Estate Planning about this. Mike Pugh told us:

“You have identified instances where legacy or internationally sourced educational material has used terminology more commonly associated with US trust law. 

Where those terms have appeared on UK-facing pages, we agree that they are not the correct terminology for English law and we are reviewing and updating older content accordingly.”

This appears to be untrue. This wasn’t “legacy or internationally sourced material”. It was Mike Pugh speaking in their own videos, for a UK audience, mixing up UK and US concepts in the same video.

A website full of “AI slop”

The MP Estate Planning website has hundreds of pages containing false claims about English law and UK tax:

  • This page says the first step of probate is to submit the Will to a probate court. There is no “probate court” in the UK – you apply for probate using a form or online. Courts only become involved in contested cases. A dozen pages on the MP Estate Planning website used to refer to probate court, in the context of UK probate. Since we wrote to MP Estate Planning, these have been changed.
  • A page on “asset protection trusts” says that life interest trusts and interest in possession trusts don’t trigger immediate inheritance tax charges – that is incorrect.
  • This page on “settlor interested trusts” is extremely lengthy, and long on generic waffle (“settlor interested trusts occupy a distinct position, offering flexibility and control.”) but its list of tax issues omits the key point that a settlor interested trust is usually something that tax planning tries to avoid because the trust settlor remains taxable on trust income, and it’s a gift with reservation.
  • This page on “how to put your house in a trust in the UK” discussed using a “revocable trust” – but that’s a US concept that has no equivalent in English law or UK tax law. Multiple pages discuss “revocable trusts”. Since we wrote to MP Estate Planning, they’ve been rewritten.
  • This page about “inheritance tax allowances for married couples” talks about the IRS $15m gift tax exemption. This page on “How much can you gift each year without paying inheritance tax” says the “The annual gift exemption allows you to gift up to $18,000 per recipient per year”. There is of course no gift tax in the UK. But the MP Estate Planning website has dozens of pages warning about gift tax.
  • Similarly, multiple pages discuss the concept of an “attorney-in-fact”. It’s not a concept in English law.
  • This page about deeds of variation goes on for pages, talks about “gift tax” and repeats meaningless phrases like “several notable cases in UK law highlight the importance of Deed of Variation regulations” (there are no such regulations).
  • A page on “Preventing Nursing Home Takeover” said “Options for funding care and government support, like Medicaid, might be available”. Medicaid is a US programme that can cover medical costs for people on low income. It is, obviously, not available to anyone in the UK. The new page is fixed.
  • There are then many pages full of misinformation, many with little to do with tax or trusts. A page about dementia, for example, incorrectly describes the laws around incapacity, and includes an entirely invented quote attributed to the Alzheimer’s Society.
  • This page says that if a UK resident gifts assets to a spouse living abroad, they may need to report the gift to HMRC. There is no such rule.
  • Then more mundane errors: a page entitled “How to legally avoid inheritance tax: 2026 edition” says business property relief and agricultural property relief provide 100% relief – that was no longer correct after the 2024 Budget.

There are over a thousand articles on various aspects of tax and trusts, and over three million words – and it’s full of errors. You can see a complete list here and here – note how the edit times are often only a minute apart (and you can also see, at the top of the second files, all the edits made after we approached MP Estate Planning in March 2026).

The obvious explanation: the website is mostly AI-generated – it’s what’s often called “AI slop“.

We expect the website was created in this way to maximise MP Estate Planning’s Google hits for people researching tax and trusts. It is, however, deeply irresponsible, because it’s providing people with false information.

If an accounting or law firm behaved in this way then we expect there would be serious regulatory sanctions. MP Estate Planning, however, is entirely unregulated.

A mysterious business failure

MP Estate Planning is not Mike Pugh’s first Will writing venture. Before that, he incorporated a company called Maplebrook Wills Ltd in 2017. It provided similar services to MP Estate Planning, as well as selling a “franchise opportunity” to use its software, brand and templates in your own business.

Maplebrook Wills never appears to have had the success of MP Estate Planning. The business filed “micro-entity” accounts for 2019, 2020, and 2021. Its final filed accounts in 2021 showed total net assets of just £85,841. It then failed to file accounts for 2022, Pugh resigned as director (replaced by someone who appears to be his wife), and the company entered liquidation.

The liquidators’ initial 2023 statement of affairs made this look like a fairly ordinary small-company collapse: about £169,000 was owed to creditors, including about £78,000 to HMRC. But the later documents suggest there may be much more to the story.

Most strikingly, the liquidators’ 2025 report says that HMRC had now submitted a claim for £1,735,520. That is an astonishing figure for a small company. The report treats that claim as unsecured, not preferential. If so, that means it is not for VAT, or PAYE income tax or national insurance (which rank as secondary preferential debts in an insolvency). The £1.7m must, therefore, be something else – most likely corporation tax and/or very large HMRC penalties.

We don’t understand how so small a company could run up a £1.7m tax liability; to owe that much in standard corporation tax alone, a business would need to generate roughly £9 million in profit (and the accounts suggest this business’s profits were less than a tenth of that figure). Whatever the explanation, something appears to have gone badly wrong. And, at the same time, the preferential debts went up to £176,807.

The impression that something went very wrong is supported by the liquidator’s report that the director and bookkeeper have failed to cooperate with investigations into the company’s final trading period:

As previously reported, my statutory investigations into the company’s affairs remained ongoing. Creditors are aware that these investigations concern the movement of the company’s assets and liabilities since the last set of formal accounts was prepared, as well as transactions undertaken during the company’s final trading period.

Throughout the reporting period, I have continued to make extensive efforts to determine whether the transactions identified during the company’s final trading period were made in the ordinary course of business. I have also continued enquiries into the movement of assets and liabilities during the same period to ensure that such movements can be accurately accounted for.

Despite repeated requests issued to the director and the company’s bookkeeper, I have not received sufficient information to progress these enquiries.

Accordingly, following the period under review, I have formally instructed my Solicitors, Freeths LLP, to assist in obtaining the information required to advance my statutory investigations. Freeths LLP are currently reviewing the material available and will advise me on the appropriate next steps in due course.

I will provide creditors with a further update in my next report.

That is unusual language for what was supposedly a straightforward small-business failure. The liquidators are investigating transactions in the final trading period, movements in assets and liabilities after the last filed accounts, and have had to instruct solicitors because they say they have not received enough information from the director and the bookkeeper. That does not tell us what happened. But it does suggest the liquidators believe there are serious unanswered questions about the company’s affairs.

We can only speculate about the detail. One notable fact is that the Maplebrook franchise business appears to have been transferred to a new company, Maplebrook EDGE Network Ltd, incorporated before Maplebrook Wills Ltd went into insolvent liquidation. It is possible the liquidators are examining whether assets were moved out of the company for less than full value. But that is just a possibility.

Currently we have no explanation why a small company with roughly £90,000 of initial non-tax unsecured creditors should suddenly owe £1.7m to HMRC.

The central mystery is a simple one: how did a company that looked, on paper, like a small will-writing business end up facing an HMRC claim of £1.7m?

This due diligence report from business intelligence firm Tech City Labs contains further information on MP Estate Planning, Maplebrook Wills, and other connected companies and individuals.

Accounts that make no sense

Here’s MP Estate Planning’s balance sheet for its first full year of trading, 2024:

MP ESTATE PLANNING (UK) LTD Registered Number 14774020
Micro-entity Balance Sheet as at 30 April 2024

Notes 2024

£

Fixed Assets 3,179
Current Assets 410,277
Creditors: amounts falling due within one year (404,280)
Net current assets (liabilities) 5,997
Total assets less current liabilities 9176
Total net assets (liabilities) 9,176

Capital and reserves 9,176

And here’s the balance sheet for 2025:

Mp Estate Planning (UK) Ltd
Balance Sheet
As At 30 April 2025

Registered number: 14774020

30 April 2025 30 April 2024
Notes £ £ £ £
FIXED ASSETS
Tangible Assets 4 2,012 209
2,012 209

CURRENT ASSETS
Debtors 5 851,986 191,829
Cash at bank and in hand 87,780 75,736

939,766 267,565
Greditors: Amounts Falling Due Within One 6 (610,191 } (153,548 )
NET CURRENT ASSETS (LIABILITIES) 329,575 114,017
TOTAL ASSETS LESS CURRENT LIABILITIES 331,587 114,226
NET ASSETS 331,587 114,226
CAPITAL AND RESERVES
Called up share capital 7 100 100

Profit and Loss Account 331,487 114,126

SHAREHOLDERS' FUNDS 331,587 114,226

The 2024 figures here bear no relation to the figures in the 2024 accounts:

  • Fixed Assets: The original 2024 accounts show £3,179. The 2024 comparative column in the 2025 accounts shows £209.
  • Current Assets: The original 2024 accounts report £410,277. The 2024 comparative in the 2025 accounts reports £267,565.
  • Creditors (due within one year): The original 2024 accounts list £404,280. The 2024 comparative in the 2025 accounts lists £153,548.
  • Total Net Assets/Equity: The original 2024 accounts state the company had £9,176 in net assets. The 2025 accounts state the 2024 net assets were £114,226.

This isn’t a rounding issue, formatting issue, or taxonomy issue. These are just fundamentally different numbers. The accounts weren’t restated, there’s no prior year adjustment, and no note explaining the reason for the changes.

We have no explanation for this.

The 2024 accounts were filed using the Companies House online service (probably by Mike Pugh or someone at MP Estate Planning). The 2025 accounts were filed using professional accountancy software by “LC Accounting”. We believe it’s this small firm in Somerset – we wrote to them asking for comment, but didn’t hear back.

The pitch and the reality

What is a trust?

MP Estate Planning, and many other unregulated firms, sell trusts as a magic box that makes your assets disappear from the taxman and your creditors. The reality is that trusts are much less mysterious, and much less able to achieve these objectives.

A trust is a legal arrangement for holding assets. The key idea is that legal ownership (whose name is on the title) can be separated from beneficial ownership (who is entitled to benefit).

Every trust has:

  • Trustees: the people (or a company) who hold the assets legally and make decisions. Trustees must act in the best interests of the beneficiaries and follow the trust deed. They can be personally liable if they get it wrong.
  • Beneficiaries: the people who can benefit from the trust (for example, by receiving income or capital, or by living in a property).
  • A settlor: the person who creates the trust and usually provides the assets.
  • A trust deed: the document setting out who the trustees and beneficiaries are, and what powers and rules apply.

Trusts are used for many legitimate reasons (for example, to manage assets for children, to provide for a vulnerable person, or to control how family wealth is distributed). But they come with real-world consequences: trustees have duties, paperwork and often ongoing administration.

Diagram connections
  • From Settlor to Trustees (Label: Transfers assets)
  • From Trustees to Trust Assets (Label: Legal Ownership)
  • From Trustees to Beneficiaries (Label: Beneficial Ownership)

Newspaper headlines often give the impression that trusts avoid tax. However, for most normal people, trusts are not good tax planning vehicles. Precisely because of their historic association with tax avoidance, successive Parliaments have built an extensive set of rules around them:

  • A gift into trust is a “chargeable lifetime transfer” – inheritance tax at 20% of the value of the property put into trust (after the £325k nil rate band).
  • The trust is then liable to an “anniversary charge” of up to 6% on its value (above £325k) every ten years.
  • If you “give away” an asset but keep the benefit (for example, you keep living in your home rent-free), tax law will often treat you as still owning it, whatever labels are used in the documents.
  • You can be hit with a capital gains tax charge when you put assets into trust.
  • The trust itself is subject to capital gains tax and income tax, and its distributions to beneficiaries are also taxed.

This is a very simplified summary of what is a very complex and frequently-changing set of rules.

The pitch

MP Estate Planning UK Ltd was founded by Mike Pugh, a Canadian who came to the UK in 2017. He claims to have a solution to “ALL THE MODERN THREATS”. Meaning: inheritance tax, care home fees, divorce and creditors:

whe MP ESTATE
‘PLANNING UK

Mike Pugh © - 2nd MP Estate Planning UK Ltd
g =

We help Homeowners in England and Wales save a MINIMUM of 3 . .

£40,000 in taxes or fees by putting their assets into a Family Assets» University of Toronto

Protection Trust Plus
Abbots Leigh, England, United Kingdom - Contact info

Protect Your Assets NOW (7

5,487 followers - 500+ connections
About

If you are a homeowner in England or Wales and you DON’T WANT your Estate to get DECIMATED by Care Fees
or Inheritance Tax...

Then, you're in the right place.

What do we do?

We help Homeowners in England and Wales save a MINIMUM of £40,000 in taxes or fees by putting their assets
into a Family Asset Protection Trust Plus before Care Fees, Inheritance Tax, Divorce or Creditors can become a
problem.

What is a Family Asset Protection Trust Plus?

A Family Asset Protection Trust Plus is a special type of trust that we've developed to protect against

ALL THE MODERN THREATS.

And not just one or the other.

What does this mean for you?

This means your estate is safe from Care Fees AND Inheritance Tax AND Divorce AND Creditors AND Probate.
Without having to worry about one benefit canceling out the other.

Who does this work for?

This works for anyone who plans ahead and puts his estate plan in place years in advance instead of waiting until
the last minute.

And somebody who is willing to invest £4000 to save £40,000 in taxes.

So if you want to protect your family and your estate from Care Fees AND Inheritance Tax AND Divorce AND
Creditors AND Probate.

Just DM me & we'll go over the details.

To your success!
Mike Pugh

Here’s a complete client proposal from MP Estate Planning:

There are four separate tax claims here:

  1. You can put assets in trust but avoid the 20% entry charge and 6% anniversary charge.
  2. You can give assets to your children but still live in your house, and avoid the “gift with reservation of benefit” (GROB) rules.
  3. Another loophole lets you give your house to your children, and still live in it, thanks to a 1999 case.
  4. And you can give your rental properties to your children, but get them to “gift” the rent back to you, so you still live off the income.

Our starting point is that lifetime trusts are poor tax planning for most people. They often result in more inheritance tax because the spouse exemption and residence nil rate bands aren’t available to trusts.

The MP Estate Planning structures we reviewed are, however, worse than that: they have no tax benefit and likely trigger a series of unnecessary tax bills.

One experienced adviser told us that the tax claims made by MP Estate Planning were so egregiously bad that they looked like fraud.

The following sections look at each of these claims. We put our criticisms to MP Estate Planning and they told us they’d respond – they didn’t.

1. “Presto magic” to avoid the 6% anniversary charge

The inheritance tax changes in the 2024 Budget created a huge demand for inheritance tax planning. That’s caused an influx of unregulated firms offering inheritance tax solutions that are “too good to be true”.

MP Estate Planning’s pitch of “every home in a trust” has the immediate problem of the 20% entry charge and 6% anniversary charge every ten years, each on value over £325,000.

But Mike Pugh has a solution: trustees can simply shift the excess over £325k out of the trust and, “presto magic” there’s no tax to pay:

We’ve seen how they implement this:

NOW THIS DEED WITNESSES THAT the Trustees shal! hold the Trust Property on trust as
follows:

1. Fund A:

Up to the maximum amount which can be held by the Trustees without inheritance tax
becoming payable by the Trustees at any time during the Trust Period for such of the
beneficiaries in Fund A in such shares and in such manner as the Trustees shail in their
absolute discretion appoint by deed or deeds revocable or irrevocable and executed at any
time during the Trust Period and in default of appointment or so far as no appointment shall
extend for the benefit of those named in Fund B below.

2. Fund B:
Subject to the above any excess is to be held on bare trust for the Settlor absolutely.
PROVIDED ALWAYS THAT:

3.1. Fund A shall not at any time exceed the available nil rate band for inheritance tax (or
any tax which may replace inheritance tax).

3.2. immediately before the death of the Settlor Fund A shall not exceed the available nil
rate band for inheritance tax (or any tax which may replace inheritance tax) after taking
into account any lifetime transfers which become chargeable on the death of the
Settlor.

3.3. Subject to the above, any excess arising on property held within Fund A shall be held
for the Settlor absolutely upon the trusts of Fund B.

This does not work:

  • An obvious point: all the claimed advantages of the trust: inheritance tax avoidance, protection against divorce and care home fees, are now limited to the first £325k of value. That’s pretty pointless, given that the first £325k of value is exempt from inheritance tax anyway. We expect most of MP Estate Planning’s clients have houses that are either worth more than that, or will likely be worth more than that in the foreseeable future.
  • It’s unclear how this is supposed to work as a practical matter; it’s even possible the trust is void for lack of certainty.
  • The fact the settlor can receive back value from the trust means that it’s classified as a “settlor interested trust”, and so there’s an up-front capital gains tax charge on the disposal of the property to the trust (unless main residence relief applies). Hold-over relief is unavailable. Any income from the trust (for example rental income) is taxable in the hands of the parent/settlor.
  • When and if the value of the trust property exceeds £325k then the way the trust is drafted means there is a reallocation from Fund A to Fund B, and a transfer of beneficial ownership to the parent/settlor. That’s probably a capital gains tax disposal at market value. So any rise in value over £325k, even just as property prices rise over time, may trigger a 24% CGT charge (although how this would work in practice is not clear).
  • One of the main purposes of the trust is to avoid the 6% anniversary inheritance tax charge. This is achieved by the Fund A and Fund B mechanism, which we regard as contrived and abnormal. MP Estate Planning promote this structure. It follows that MP Estate Planning had an obligation under the Disclosure Of Tax Avoidance Schemes rules to disclose the structure to HMRC. We understand that they did not.
  • This trust could well mean that the parents lose the main residence capital gains tax exemption (because they no longer own the house). That’s a serious tax downside which MP Estate Planning never mentions.

We discussed this structure with a leading tax KC – he said he thought the trust was “a poorly drafted mess and would cause more problems than it solved”.

2. Avoiding GROB with a school uniform

The most obvious inheritance tax planning is to give your house and other valuable assets to your children – provided you live for seven more years, the assets are outside your estate.

You are perfectly entitled to do this if you are really making a gift. But if the gift is just on paper, and you continue to benefit from the property, then your “gift” is ignored for inheritance tax purpose thanks to the “gift with reservation of benefit” rules. The classic example is: I give my house to my children, but I continue to live in it. It’s a “gift with reservation of benefit” and disregarded.

MP Estate Planning say there’s an easy solution:

Mike Pugh is referring to the rule in section 102B(4)(a) Finance Act 1986 – it was introduced specifically for the situation where an adult child lives with a parent to look after them:

102B Gifts with reservation: share of interest in land.

(1) This section applies where an individual disposes, by way of gift on or after 9th March 1999, of an undivided share of
an interest in land.

(2) At any time in the relevant period, except when subsection (3) or (4) below applies—

(a) the share disposed of is referred to (in relation to the gift and the donor) as property subject to a reservation;
and

(b) section 102(3) and (4) above shall apply.
(3) This subsection applies when the donor—

(a) does not occupy the land; or

(b) occupies the land to the exclusion of the donee for full consideration in money or money’s worth.
(4) This subsection applies when—

(a) the donor and the donee occupy the land; and

(b) the donor does not receive any benefit, other than a negligible one, which is provided by or at the expense of
the donee for some reason connected with the gift.

The key elements are that there is a gift of an undivided interest in land (e.g. “parent gives half the property to the child”), the donor and donee occupy the land and the donor doesn’t receive a benefit from the gift.

The first thing MP Estate Planning get wrong is that they don’t know what an undivided interest in land is. Here’s their attempt to create one:

———

_ (NOW THIS DEED WITNESSES as follows:

The: Legal Owner DECLARES ‘that he: holds the Property ona trust of fand.

‘The-Legal Owner DECLARES that he. holds the Property and its proceeds of'sale
{after ischarging: the’ Mortgage: ‘and: deducting the. Costs. of: Sale) and the j income from: it.

UPON TRUST ; as: tenants in’ common: .

One person cannot hold as “tenants in common”. It’s a hopeless failure to get within section 102B.

Even when they get that right, MP Estate Planning have a bizarre idea of what the word “occupy” means:

The FOUR Tests To Qualify For This Planning

Does your child live elsewhere and come round
more frequently than Easter and Christmas.
Perhaps they spend some weekends and same
holrdays there?

Does your child keep some of their personal

possessions at the address? Pictures from
childhood? An old school uniform? Storage of

personal possessions and a right to use with
minimal actual occupation can constitute
occupation for those purposes.

Does your child have access to the property and
has the keys to come and go as they please or they
know the passcode or location of the secret key?
Do they have the right and freedom to come and
go as they please?

This is an odd precedent: Do they pay or
contribute less than 50% of the utilities and
maintenance of the property?

No benefit is to be provided at the expense of the donee. Your child must not overpay for their use of the property. Indeed,
the safest course is for the original owner to pay all the running costs - council tax bill, gas and electricity, cleaning, TV

licence, maintenance - and the capitat outlays also.

Long answer short: If you can answer YES to all the above - OR even better - your child is still lives with you and is over 18, the
gift of the undivided share in the property to your children will avoid the gift with reservation of benefit (GROB) provisions.
This is a proven strategy and can reduce the IHT footprint on a principal residence by 50%.

In other words, they think that a child will “occupy” the land for this purpose if they visit their parents occasionally, keep belongings in the house (such as a school uniform), and have access to the property and a key. That is contrary to the normal human meaning of “occupy”. Some advisers interpret the section as permitting children to live elsewhere primarily, provided they visit most weekends and holidays. However MP Estate Planning’s view that you “occupy” a property if you visit it a few times a year goes far beyond anything our team has seen.

We therefore view this planning as well outside mainstream tax planning; we believe HMRC would challenge it if they became aware of it, and we don’t think the taxpayer would have any material prospect of success.

MP Estate Planning suggest the planning is more effective if the child receives the gift and then lives with the parents. That is obviously correct – indeed the planning works if the child lives with the parents (and in our view that would continue to be the case if, for example, the children were at university but retained a bedroom at their parents’ house, and stayed there for some weekends and most holidays). However the problem is that children tend to leave, and at that point the reservation of benefit rules will apply.

We believe one of two things are happening. Either MP Estate Planning has misread “occupy” in s102B(4)(a) as “able or entitled to occupy” (the test in a preceding section), and don’t realise that section 102B(4)(a) requires actual occupation. Or this is an attempt to fool HMRC with a school uniform.

One experienced adviser described it to us as “utter nonsense”. Another, a tax KC with trusts tax expertise, said “it doesn’t look like they’ve read the legislation”.

There is a further even more obvious problem. We’ve seen a case where MP Estate Planning advised that the “occupy” strategy worked to prevent a gift with reservation of benefit where property was put in trust. It cannot. Section 102B(4)(a) requires that the “donee” occupy the property. When property is declared on trust then the “donee” is the trust, and a trust can’t occupy anything. This point is usually well⚠️ understood by advisers.

3. Using a 1999 licence loophole that doesn’t exist

MP Estate Planning claim to have found another loophole, and one which has existed since 1999:

Mike Pugh is very vague here, but we’ve seen documents where Estate Planning claim that you can put your home into a trust, exclude yourself as a beneficiary, but still carry on living there under a “trustee licence”. They say this means there is no “gift with reservation of benefit”.

We saw an email to a prospective client in which an MP Estate Planning employee said:

“The design allows the settlor to retain occupation under a trustee licence, not a beneficial right — ensuring no ‘gift with reservation’…

No rent or benefit is reserved.”

This is a hopeless argument. The gift with reservation rules look at whether you have given away the property whilst still “enjoying” it. The legal form used – lease, licence, or anything else – is entirely irrelevant.

There is a straightforward, well‑known way to make a gift of a home effective while you keep living there: you pay the new owner a full market rent for the rest of your life. The legislation expressly allows for this. MP Estate Planning’s pitch is the opposite: they say there is a “trustee licence” and “no rent”. If that is what happens in real life, it is hard to see how the arrangement can be anything other than a reservation of benefit.

The 1999 case they refer to is Ingram v IRC (1999). The case is nothing to do with licences vs leases (there is a nice explanation of Ingram here), but in any event Ingram was effectively overriden by legislation in 1999.

Quite aside from not working, the structure has the significant downside of losing the parents’ main residence capital gains tax exemption.

There may again be an obligation for MP Estate Planning to disclose the scheme to HMRC under DOTAS; we understand that they have not done so.

A tax KC we spoke to described MP Estate Planning’s approach as “baffling”, saying “I have no idea what they think this can achieve”.

4. Gifts that ignore an anti-avoidance rule

In principle it’s easy to avoid inheritance tax: just give your assets to your children. But there’s an obvious problem: most retired people who have assets live off the proceeds of the assets.

MP Estate Planning say you can have your cake and eat it: put rental properties into a trust, but still receive the rent from the properties:

Income Tax
Most homes do not generate income - therefore there is no income tax issue.
On BTL's and second properties there is often income

Problem: How to deal with the income from the second properties without triggering a GROB? The answer can be found in
your MP Estate Protection Plan® Second Property Trust.

Here's how they work:
The trust can declare the income and pay the 45% income tax - often considered suboptimal.
OR

The income from the second property is MANDATED by the Second Property Trust trustees to the beneficiaries. The
beneficiaries of the Second Property Trust on the second property declare all the income on their self-assessment. The
income can be spread among the beneficiaries to help keep them below the thresholds.

Trustees will not normally need to complete a tax return for trust income if it is all mandated directly to the beneficiaries.
The beneficiaries can then GIFT the income back to the parents.

This is done via [HTA 1984 521 and is called a ‘Gift of Surplus Income‘
Gift of Surplus Income

The beneficiaries, after declaring the income on their self-assessment, may then choose of their own free will to gift the

income to anyone they choose.

‘Section 21(1) Inheritance Tax Act 1984 allows an individual to make Inheritance Tax exempt gifts provided the gifts can be
characterised as being: part of the donor's normal expenditure; made out of the donor's incame, taking one year with
another.’ In ather words: A Gift of Surplus Income.

If there is any hint that there is a written arrangement in place, the planning will potentially fall foul of the associated
operations provisions (IHTA 1984 $268). The surplus income must be a GIFT and a voluntary gift. Even better would be for the
beneficiary to purchase something on behalf of the giftee: a holiday for example, new white goods etc.

The idea is simple: the trust mandates the rental income to the beneficiaries (the children) and they pay tax on it, and then give the money back to their parents.

And MP Estate Planning say that, as long as there’s no written agreement, it’s fine:

“If there is any hint that there is a written arrangement in place, the planning will potentially fall foul of the associated operations provisions (IHTA 1984 s268).”

This is very wrong.

The “associated operations” rules allow HMRC to treat a series of connected transactions and steps as a single arrangement when determining whether a transfer of value (like the gift of rental properties) has taken place.

Here’s the definition:

268 Associated operations.

(1) In this Act “associated operations” means, subject to subsection (2) below, any two or more operations of any kind,
being—
(a) operations which affect the same property, or one of which affects some property and the other or others of

which affect property which represents, whether directly or indirectly, that property, or income arising from that
property, or any property representing accumulations of any such income, or

(b) any two operations of which one is effected with reference to the other, or with a view to enabling the other to
be effected or facilitating its being effected, and any further operation having a like relation to any of those
two, and so on.

whether those operations are effected by the same person or different persons, and whether or not they are
simultaneous; and “operation” includes an omission.

There is no requirement in the legislation, caselaw or HMRC guidance that the “operations” in question are in writing (and HMRC give an example in their guidance where successive gifts are subject to the rules).

In HMRC v Parry, the Supreme Court held that, applying Macpherson, the associated operations rules may apply if steps form part of and contribute to a scheme intended to confer a gratuitous benefit. Whether such a scheme exists is a question of fact, and may be established by evidence showing how the steps were intended to operate together; it does not require a formal written arrangement.

In this case there is clearly a scheme: the gift of the properties and the return of the income are clearly intended to operate together. This, after all, is what MP Estate Planning are selling. We therefore think it’s reasonably clear the “associated operations” rules will apply, so that for inheritance tax purposes the gift and the return of income would be analysed together as a single scheme.

The effect is that the arrangement must be analysed as a single scheme, so that (for inheritance tax purposes) the parents continue to benefit from the rental income. The ‘gift with reservation of benefit’ rules will, therefore, immediately bite. The consequence is that the full capital value of the properties will be treated as still belonging to the parents’ estate when they die, and heavily taxed. The structure therefore fails in a rather messy, entirely pointless, and highly expensive manner.

High risk landlord tax planning

MP Estate Planning seems to be trying to move into general tax planning for landlords, and are adopting some planning that we would characterise as extremely high risk.

A slide from an MP Estate Planning podcast is suggesting that a landlord holding properties directly could form a partnership for a year, then incorporate the partnership, and have no capital gains tax or stamp duty:

lf you have a property portfolio with 4 or more
properties, did you know it’s possible to:

© Reduce the 40% Inheritance Tax rate to *
# Reduce the 24% Capita) Gains Tax rate to
# Reduce Stamp Duty to 1

(UR approach
1, Paromita 1 Yam]
2 lncarparation

3 teu thereafter)

4. Share Plann

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Ngee FOR SALE

The idea appears to be that the landlord first transfers their properties into a newly-created partnership – so, for example, if they own property with their spouse, the married couple are the partners in the partnership. They run that partnership briefly, and then transfer the partnership business to a company. The promoters claim that this avoids capital gains tax, stamp duty land tax and inheritance tax.

This planning is extremely high risk.

In principle a partnership can in some circumstances incorporate its real estate business without stamp duty land tax – but if there is a scheme of transactions to establish the partnership and then incorporate then the section 75A anti-avoidance rule means that SDLT will likely apply. If someone is obtaining the advice in this slide from MP Estates then it will be reasonably clear there was a prior arrangement. Waiting one year, or five years, makes no difference.

The capital gains tax planning could in principle succeed – there is potentially incorporation relief on the transfer of a business to a company. However it is a technical and difficult relief which normally requires the landlord to be carrying on a genuine property business, not merely holding investment properties, and can be hard to apply where the property is mortgaged. HMRC are scrutinising incorporation relief claims at the moment, and the law is about to change to require incorporation relief claims to be filed with HMRC.

We would suggest landlords carefully consider whether the tax and other benefits of incorporating justify the risk of high capital gains tax and stamp duty land tax charges. A competent tax adviser will always explain the level of risk and the worst case downside. When an adviser doesn’t do this, in our view it raises a large red flag.

Saving probate costs

Elderly people are often worried about the future costs of probate. Mike Pugh says they should be, and his trusts can solve the problem:

“By putting your largest asset into a trust, you can help to reduce future probate costs, as probate’s often geared on the size and complexity of the estate.

If your house doesn’t form part of the estate, it doesn’t form part of the price analysis.”

In our view the opposite is the case: the complexity caused by MP Estate Planning’s trusts will greatly add to the cost of probate. That would be the case even if the trusts were correctly structured and drafted – but they are not. We are aware of one case where the heirs of an MP Estate Planning client had to engage a KC at great cost to resolve the difficulties MP Estate Planning had caused.

The Society of Will Writers tells its members not to make this claim:

2) “This type of trust will save probate fees.”

The rationale behind the statement is that where professionals have been engaged to
deal with probate, and their fee is based on a percentage of the estate, the percentage is
reduced by the trust falling outside the estate.

[tis impossible to know whether the executors would choose to engage a firm with that
fee structure in the future. Furthermore, by passing assets into trust, you are creating a
‘Gift with Reservation of Benefit’ and in most cases making the settlor a beneficiary of
trust assets of over £250,000. This will prevent the estate from being an excepted estate
under the HMRC rules and will necessitate the completion of a full IHT 400 return at the
time of death. This may increase probate costs, not reduce them, if the executors
require professional assistance.

Members must not make this claim in advertisements and promotions.

Divorce protection

MP Estate Planning heavily markets their trusts as a way that can financially support your children after you die, but if your children divorce then their spouse will have no claim on their assets:

“The divorce rate in the UK is 42%. What if your child gets a divorce? Your child’s future Mr. or Mrs. Wrong could walk out with half your life savings if your assets are not in a trust. Don’t leave money to children. Leave it to a trust. A trust will never get a divorce. A trust is the only thing we have that will make money stick to blood”.

We spoke to barristers and solicitors specialising in chancery law, family law, and nuptial agreements, and they all expected the trust would fail to achieve this.

  • Divorcing spouses have been successful in arguing that an ex-spouse’s ability to benefit from a trust is a matrimonial asset (even where it’s a discretionary trust) and should be part of the divorce settlement. Courts can and do make orders reallocating trust assets.
  • The decided cases have involved trusts where the trustees were genuinely independent, and beneficiaries could therefore argue that they weren’t necessarily going to have access to the trust assets. In the MP Estate Planning trusts we reviewed, the beneficiaries are also the trustees – the trusts are therefore highly vulnerable to attack in divorce proceedings. They’re simply part of the “property and other financial resources of the child, and part of the “matrimonial pot” in the same way as any other asset. The arrangement achieves nothing.
  • The courts often don’t need to award trust assets to a spouse – they can simply adjust the allocation of other assets to reflect the expected value of a trust interest (although this “judicial encouragement” doctrine has limits).

The Society of Will Writers tells its members not to make this claim:

6) “This type of trust will protect the trust assets in the event of your
beneficiaries’ divorce.”

$25 Matrimonial causes act states the court may take into account - The income,
earning capacity, property and other financial resources which each of the parties to the
marriage has or is likely to have in the foreseeable future (including any benefits under a
pension scheme which a party to the marriage has or is likely to have), including in the
case of earning capacity, any increase in that capacity which it would in the opinion of
the Court be reasonable to expect a party to the marriage to take steps to acquire.

This includes trust assets that have been ‘Matrimonialised’ or ‘Nuptialised’.

This claim is not to be made without making the distinction clear.

Bankruptcy protection

Mike Pugh promises that trusts will protect your estate from insolvency (as well as divorce and care home fees; more on that below):


So what happens if you do not set up a trust?

Well, if you own anything, it can be taken from you.

If you don’t own it, it can’t be taken from you. And that’s what a trust does.

A trust removes you as the sole legal owner of an item. Therefore, you can’t lose it in a future divorce or to care fees or to taxes or litigation or bankruptcy.”

Similarly, their October 2025 proposal lists “Protection against future Bankruptcy” as one of the primary benefits of the “MP Estate Protection Plan”.

This is all variant of the “deed in the drawer” structure that’s been used for centuries. As one judge summarised it:

“The phenomenon of the “deed in the drawer” is one that is now frequently encountered. X appears to be the owner of a property, and people lend to him or otherwise deal with him on the footing that he owns it. But if X becomes bankrupt or the subject of enforcement proceedings a deed is produced which shows that in truth he holds the property upon trust for somebody else. In some cases these deeds are simply not authentic. In other cases they are authentic, but simply not noted in any public register.”

This is misleading. First, for almost all the elderly people MP Estate Planning are targeting, bankruptcy is not something they realistically should be worrying about (the bankruptcy of their children is a more reasonable concern; but that’s not the claim made in the above video).

Presenting bankruptcy as a “modern threat” is scaremongering. But if someone does go bankrupt, it is absolutely not the case that they “can’t lose” property if it’s in a trust:

  • Gifts into a trust will be set aside if made within two years of your bankruptcy, or five years if you were insolvent at the time.
  • A gift made at any time can be set aside if a court is satisfied that the gift was made for (amongst other things) the purpose of putting assets beyond the reach of a person who is making, or may at some time make, a claim against him.
  • Given the explicit marketing claims made by MP Estate Planning, it would be difficult to argue that protecting assets from creditors was not a primary purpose of setting up the trust.

The Society of Will Writers tells its members not to make this claim:

9) “This type of trust will protect your assets from Bankruptcy.”

Similar to deliberate deprivation of assets for care costs, the Insolvency Act 1986
addresses the subject of putting assets beyond the reach of creditors, which this type of
trust could potentially do. In this case, the trustee in bankruptcy can set aside the
transfer and seek the permission of the court to recover the trust assets.

Members must not make this claim in advertisements and promotions.

Care home costs

The rising cost of social care is a significant financial challenge for local authorities, and now accounts for 40% of all local authority spending. To try to control this, almost all local authorities only cover the cost of social care for people with assets of less than £23,250. It has been politically challenging to find a better solution. In the meantime, firms like MP Estate Planning market trusts as a solution to avoid having to pay for social care. The idea is to reduce your assets to below £23,250, or at least make sure your house never forms part of those assets.

There are rules in the Care Act which disregard any steps people take to avoid these rules deprive themselves of assets. MP Estate Planning appears to have not read these rules.

In this video, Mike Pugh says people who’ve been diagnosed with a serious illness should put their property into trust, and that will stop local authorities assessing them to make a contribution if they later require long term care.

He for some reason starts talking about the Insolvency Act (which is irrelevant):

“So let’s remember that the CARE Act states that only if there’s a foreseeable need for care would you be crossing any lines…

Let’s clear up the misunderstandings around deliberate deprivation.

The deliberate deprivation stems from the Insolvency Act. It is criminal to try to hide assets from creditors. That’s a criminal offense. And so if you’re going to go bankrupt under the Insolvency Act, you’re not allowed to place assets into a trust.

Here, what we’re talking about, however, is a potential future care element. That means there are no creditors today. You don’t owe any money for care, you’re not in care, and there’s no foreseeable need for care. So that means you are welcome to place your property in the trust now.

The statute has a simple purpose test:

Notional capital

22.—(1) The adult is to be treated as possessing capital of which the adult has deprived themselves for the purpose of decreasing
the amount that they may be liable to pay towards the cost of meeting their needs for care and support, or their needs for support,
except—

(a) where that capital is derived from a payment made in consequence of any personal injury and is placed on trust for the
benefit of the adult;

(b) to the extent that the capital which the adult is treated as possessing is reduced in accordance with regulation 23; or

(c) any sum to which paragraph 44(1) or 45(a) of Schedule 10 to the Income Support Regulations (disregard of compensation
for personal injuries which is administered by the Court)(1) refers.

The statutory test is not “foreseeable”. That word is taken from the statutory guidance:

12) For example, it would be unreasonable to decide that a person had disposed of an
asset in order to reduce the level of charges for their care and support needs if at the
time the disposal took place they were fit and healthy and could not have foreseen the
need for care and support.

Example of assets to be considered
Mrs Kapoor has £18,000 in a building society and uses £10,500 to purchase a car. Two
weeks later she enters a care home and gives the car to her daughter Juhie.

lf Mrs Kapoor knew when she purchased the car that she would be moving to a care
home, then deprivation should be considered. However, all the circumstances must be
taken into account so if Mrs Kapoor was admitted as an emergency and had no reason
to think she may need care and support when she purchased the car, this should not be
considered as deprivation.

This is just making the point that foreseeability is relevant when determining what the “purpose” of a transaction was. We don’t believe the guidance anticipates a trust structure being sold specifically to avoid paying care charges. The courts in practice determine “purpose” from surrounding circumstances. In the view of Care Act specialists we spoke to, it would be reasonable for a local authority to decide that someone who’d bought the MP Estate Planning structure had “deprived themselves for the purpose of decreasing the amount that they may be liable to pay towards the cost of meeting their needs for care and support”. Local authorities could obtain disclosure of MP Estate Planning’s advice in order to establish this.

They’d be aided in this by the statutory guidance, which gives putting assets into trust as a specific example of “deprivation of assets”:

Has deprivation of capital occurred?

8) It is up to the person to prove to the local authority that they no longer have the
asset. If they are not able to, the local authority must assess them as if they still had the
asset. For capital assets, acceptable evidence of their disposal would be:

(a) a trust deed

(b) deed of gift

(c) receipts for expenditure

(d) proof that debts have been repaid

9) A person can deprive themselves of capital in many ways, but common approaches
may be:

(a) a lump-sum payment to someone else, for example as a gift

(b) substantial expenditure has been incurred suddenly and is out of character with
previous spending

(c) the title deeds of a property have been transferred to someone else
(d) assets have been put in to a trust that cannot be revoked

(e) assets have been converted into another form that would be subject to a disregard
under the financial assessment, for example personal possessions

(f) assets have been reduced by living extravagantly, for example gambling

(g) assets have been used to purchase an investment bond with life insurance

Some local authorities have expressly identified “lifetime trusts” (like those created by MP Estate Planning) as examples of asset deprivation. It’s notable that the people selling these trusts are almost always unqualified and unregulated, whilst actual qualified solicitors warn against them.

It is therefore quite wrong for MP Estate Planning to confidently suggest it’s all about “foreseeability”, and ignore both the wording of the statute and the references to trusts in guidance:

Protection from Care Fees

Without proper planning, care fees can significantly deplete your estate, leaving little behind for your loved ones
Our plan can help to protect your assets from the high costs af long-term care, allowing you to pass on the
wealth you've worked hard to build. By using trusts and other estate planning tools, we can try to ensure that
your estate remains intact, regardless of your care needs in the future.

The two keys to this are that you are not setting up a trust solely to avoid care tees, there must be other
legitimate concerns that you are protecting against - divorcing children being a good example - and you establish
the planning sufficiently far in advance of care that there is no foreseeable need for care or support as per the

Care Act 2014
Pro's

€te €¢ €¢€ €¢ € £€ € ¢

CARE FEES Protection for 100% of Home
Care Fees Protection less than 1 Mth of Care
Retains your MAXIMUM TAX RELIEFS
Protect against future Divorce in the family
Protection against future Bankruptcy
Defence against Litigation

Stops HMRC from Generational IHT
Guardianship for Minor Children

Eliminates Family Contention

This is a particularly egregious error because the video above flashes onto the screen a clip from guidance from Age UK, which makes clear that it’s fundamentally the intention behind a disposal which is relevant:

4 When is deprivation deliberate?

The guidance advises loca! authorities to understand that avoiding your
assessed care charges may not be the only motive behind the disposal
of eligible capital or income ahead of your financial assessment. There

may be justifiable reasons, so the loca! authority must show why it has

come to a deliberate deprivation conclusion.

Intention

Your intention to avoid your care charges must be a significant factor,
or the only reason, you have disposed of an asset, in order to be found
to have deliberately deprived yourself. The local authority must justify
their decision if they intend to take a disposed asset into account.

Foreseeability

Annex E of the guidance states it is unreasonable to decide you have
disposed of an asset to reduce the level of care charges payable if, at
the time of the disposal, you were fit and healthy and could not have
foreseen a need for care and support.

AFORESEEABLE NEED FOR

The Society of Will Writers tells its members not to make this claim:

1) “This type of trust will protect your home from paying care fees.”

The rules that cover care costs and deliberate deprivation of assets are complex, and
specific to the circumstances of the individual. When considering the transfer to trust a
Local Authority will take into account a number of factors —

e why and when the settlor disposed of the assets.

@ whether they could have known that they would need care and support at the
time of the transfer.

« whether they expected that they would have to pay towards their care costs.

® whether avoiding care costs was a significant motivation for disposing of the
assets.

The Society’s view is that by simply making this claim you are potentially providing the
local authority with proof that avoiding care costs was a significant motivation.
The consequences of this can be severe — the Local Authority can apply to the courts to
‘set aside’ the transfer to trust and treat the asset as though the settlor still owned it for
the purposes of calculating care fees. This means that the settlor will be deemed to own
the full value of the property and therefore be responsible for the payment of their own
fees.

However, as the property is in the trust and is no longer legally owned by the settlor, this
cannot be undone without incurring costs and potential difficulties. Depending on how
the trust has been set up, the settlor may no longer have direct access to the asset that
the LA has used in the assessment. The settlor might be entirely reliant on the trustees’
actions.

Members must not make this claim in advertisements and promotions.

The trust defaults the mortgage

MP Estate Planning claim that you can put a property into trust without telling your mortgage lender. This is false. Most standard residential mortgages contain strict covenants prohibiting the borrower from transferring interests in the property (including beneficial ownership) without the lender’s express written consent.

As UK Finance told us when we investigated another trust structure in 2023:

“Transferring ownership of a property into a trust without informing your lender and seeking their consent would most likely be a breach of a mortgage’s terms and conditions.”

MP Estate Planning go further, and claim you can mortgage a property that’s already in a trust:

“The property can be taken out of the trust, mortgaged, and then put back into the trust”

This is very poor advice.

Taking the property out of trust doesn’t fix the fundamental problem that most mortgage terms prohibit transferring ownership of the property.

But it’s worse than that. There are now potentially two capital gains tax events (the trust disposing of the property to the parents, and the parents disposing of it back into the trust). If the value of the trust is over £325,000 then pulling the house out triggers an IHT exit charge. Then, when they put the house back into the trust after getting the mortgage, it triggers a new 20% IHT entry charge (on the value over £325,000). Their “simple” workaround could easily cost the client hundreds of thousands of pounds in tax every time they want to fix their mortgage rate.

Here’s a nonsensical explanation we saw from MP Estate Planning:

* You do not nee to inform your mortgage company, for the simple reason that it is your
equitable value that is in the Trust and NOT the mortgage amount or market value. You are
still the beneficial owner of the property and the bank/mortgage company, the legal
owner.

The “equitable value” is not a legal concept. The mortgage amount and the market value are almost always different. The lender is not the “legal owner” of the property. A real estate law specialist we spoke to concluded that whoever wrote this has no understanding of mortgages.

Incompetent advice

We have seen a series of badly drafted documents and incompetent responses from MP Estate Planning personnel:

We saw one trust where a mother was declaring a trust with her daughter as a trustee and discretionary beneficiary. The trust document listed the daughter as the settlor. When challenged on this, the adviser at MP Estate Planning didn’t appear to understand the difference between a settlor and a trustee.

An MP Estate Planning adviser did not understand that the fact value could pass back to the settlor made it a settlor-interested trust. He responded that “Any tax related matter should be dealt with by an accountant”: but no accountant was involved when they established the trust.

We also saw one trust deed with one of the worst drafting errors we’ve seen:

— 0 ofand construed according to: the: law of England: and Wales.

in acknoviledg ment of the provisions of this settiement: the Settlor and the, Initial
OS ‘Trustees havejexecuted this document < asa: deed in the presence of witnesses onthe

Under the “Exclusion of Settlor and Spouse” there should be a clause preventing the settlor and their spouse ever benefiting from the trust. This is necessary to prevent the settlor interested trust rules applying, causing (amongst other effects) an up-front capital gains charge. But instead someone accidentally duplicated the text of the next clause (“Applicable Law”) into “Exclusion of Settlor and Spouse”. That’s a serious error, because it means the trust likely will be a settlor interested trust.

And, as noted above, we saw another deed where MP Estate Planning tried to create ownership as tenants in common, and failed (because they didn’t realise that requires two or more people):

———

_ (NOW THIS DEED WITNESSES as follows:

The: Legal Owner DECLARES ‘that he: holds the Property ona trust of fand.

‘The-Legal Owner DECLARES that he. holds the Property and its proceeds of'sale
{after ischarging: the’ Mortgage: ‘and: deducting the. Costs. of: Sale) and the j income from: it.

UPON TRUST ; as: tenants in’ common: .

It’s believe of our team that this kind of error is most likely caused by people with no legal qualifications drafting complex legal documents. Drafting trusts over land is a “reserved activity” that can only be conducted by solicitors and certain other qualified professionals – if unqualified staff are indeed drafting these documents then that’s a criminal offence.

The scale of the problem

A recent recruitment video claims that, in the first six months of 2025/26, MP Estate Planning made £1.66m in fees, with huge growth year-on-year. That implies they’ll bill at least £3m in fees this year.

What lop Closers Want Ilo See -

Growth

A company scaling fast with verified momentum.

A market opening wider every year.

An income opportunity that compounds as we expand.

A business model where elite performers rise quickly.

This is what momentum looks like and we're still early.

Profit and Loss

MEE atare Panny ett

Dew tre wae orate WI Agee Meh

a 3] 1660 100 46 Vet 77 62 478 162 8

strong

Documented Revenue
Growth (2024 — 2026 YTD)

2023/2024: £479k
2024/2025: £1.46M (+300%)
2026 YTD: £1.66M+
(+500%)

Passed Last Year
with 6 months to go!

We NP ESTATE
*Q PLANNING UK

Reaititvwthicchie WwW

Every Home In A Trust

MP Estate Planning are unusual in publishing their pricing on their website:

Product

Wills
Single WilL
Mirrored Wills
Family Home Protection Wills (FHPW)

Lasting Power of Attorney (LPA)
Property & Finance
Health & Welfare

Will Trusts
WiLL Trust Single
Will Trust Couple

Lifetime Trusts
(Estates Under £325k or £650k)
Family Home Protection Trust (FHPT) (Single)
Family Home Protection Trust (FHPT) (Couple)

Lifetime Trusts
(Estates Over £325k or £650k)
Family Home Protection Trust PLUS (FHPT+) (Single)
Family Home Protection Trust PLUS (FHPT+)(Couple)

Trusts with [HT Planning
(Estates Over £1m) (Added to FHPT+ Price):
Gifted Property Trust (GPT}(Single)
Gifted Property Trust (GPT)}(Couple})

Trusts with [HT Planning
for Non-Main Residence Properties
Second Property Trust (SPT)

Other Documents & Services
Educational Gift Trust
Life Insurance Beneficaries Trust
Deed of Variation
HMLR First Registration
Non-Mutual SEV
Deed of Trust
Continuing Support
EstatePro® Report

2025 Price List

£420
£720
£1,800

£420
£420

£1.385
£2.580

£4,050
£4,740

£4.740
£5,340

£2,370
£2,670

£4,050

£2.673
£1,337
£2,070
£1,250
£450
£840
£750
£500

Plus Disbursements

Includes Severance of Tenancy (SEV)

Excludes Registraton Fees

Excludes Registraton Fees

Includes SEV

Plus Land Registry (HMLR) Registration
Plus Land Registry (HMLR) Registration

Plus Land Registry (HMLR) Registration
Plus Land Registry (HMLR) Registration

Plus Land Registry (HMLR) Registration

However, most of their clients are buying multiple products, and so these prices quickly add up – we understand overall fees in the tens of thousands are common (and indeed that would be necessary for a team of this size to make £3m in revenue). Mike Pugh says:

“I do know that my competitors that offer the sophisticated high end stuff, they tend and – I’m talking Magic Circle and inside the M25 – they tend to charge either two percent of asset value or 10 percent of tax savings.

If you’re saving five million pounds, they could charge up to half a million… and I’m nowhere near the M25 – I’m in Bristol and we do not charge big city prices.

So we’re in the tens of not the hundreds of thousands.”

The claim that firms charge 2% of asset value or 10% of tax savings is, in the experience of our team, not correct. Legal/tax fees of £500,000 would be for very large estates, not people worth “mere” millions.

The response from MP Estate Planning and Mike Pugh

We asked MP Estate Planning to respond to the most significant points in this report:

Here’s our original email asking for comment:

From: Dan Neidle 

Subject: Request for comment - report on MP Estate Planning
Date: 5 March 2026 at 15:47:32 GMT

To: answers@mpestateplanning.uk

Dear Sirs and Madams

I’m an investigative journalist and tax lawyer, and the founder of Tax Policy Associates - a think tank
established to improve UK tax policy.

We are investigating firms that are marketing trust solutions that do not appear compliant with English
law or UK tax law.

We will be publishing a report on your firm next week, and wanted to give you the opportunity to
comment on our provisional findings.

They are as follows:

1. Structures that don’t work

You promote and implement a number of structures which in our view ignore well established legal
and tax principles and, in the view of our very experienced team, have no realistic prospect of
working.

These include:

¢ Aclaim that s102B(4)(a) FA 1986 can apply where a child visits their parent a few times a year.
That is nonsense - there needs to be “occupation” - the usual view is that living in the property at
weekends and over holidays is the minimum. Even more concerning, you seem to think s102B(4)
(a) can apply where property is put in trust - it cannot. The “donee” must occupy, and a trust
doesn’t occupy anything.
Aclaim that you can put your home into a trust, exclude yourself as a beneficiary, but still carry on
living there under a “trustee licence”. You say this means there is no “gift with reservation of
benefit”, and cite the 1999 Ingram case. This is nonsense. This is not the Ingram structure (which
was in any case overriden by legislation). A licence is within the GROB rules
An attempt to avoid IHT charges on trusts using a structure where trust is declared over the
parents’ house, with any excess over £325k held on bare trust back to the parent/settlor. The
obvious problem: this is a settlor interested trust. A further problem: the transfers back of any
excess will be CGT events. There may be SDLT complications as well.
Aclaim that clients can declare a trust over mortgaged property. Most mortgage terms prohibit this
(and UK Finance has publicly said this). In one you suggest that people can take the house
out of the trust, mortgage it, and then put it back into the trust. This looks like mortgage fraud.
e Multiple claims that someone won't have to contribute to the costs of care, and the “deprivation of
assets” rule won’t apply, if a trust is put in place when there is no foreseeable need for care. That
is not what the law says. The test is one of purpose: and your trusts are marketed with the
purpose of avoiding care contributions.

Many of these structures should be disclosed to HMRC under DOTAS. Our understanding is that you
make no DOTAS disclosure

We also haven't seen a single case where you provide clients with written tax advice. You speak to
them on Zoom calls and then send documents, but never explain which rules apply, and never
discuss risks.

2. Basic lack of knowledge
Your website and YouTube channels suggest that your firm lacks a basic understanding of UK tax and
English law.

In this video, Mike Pugh doesn’t seem to realise that the main residence is exempt from capital gains
tax. He ignores the fact that putting a £900k property in trust will trigger an immediate £115k IHT hit.
https://taxpolicy.org.uk/wp-content/uploads/2026/03/doesnt_understand_cgt.mp4

In this video, Mike Pugh says there's stamp duty if parents gift their home to their children. There isn't.
https://taxpolicy.org.uk/wp-content/uploads/2026/03/Can-|-buy-my-parents-house-to-avoid-
inheritance-tax%EF%BC%9F-IJ1aLgAQ3rM.mkv

Many of your videos and pages on your website refer to “irrevocable” and “revocable” trusts. These
are US concepts with no UK equivalent. Many pages on your website refer to the need to apply to a
“probate court”. There is no such requirement in the UK, and no such thing as a probate court.

3. Misleading claims
Your website says you “work in conjunction with the Chartered Insurance Institute”. We have spoken
to the CIl; neither your firm nor any individual there is a Cll member.

The claimed award from "Legal Directorate” isn’t real. Legal Directorate is a “pay for play” directory
which uses Al to generate fake reviews. They didn’t even bother to update it when the business was
phoenixed from Maplebrook Wills - the url is still "https://legaldirectorate.co.uk/company/maplebrook-
wills-441174401555-weston-super-mare/"

You claim to have special permission from James Kessler KC to use his precedents. Our
understanding is that this isn’t true.
4. Unregulated and unqualified staff

We believe you have no staff with any legal, tax or accounting qualifications. You say in one video
that your head of legal is a doctor of law specialising in taxes and trusts - but your website doesn’t list
a “head of legal’.

It follows that you are unregulated and uninsured.

5. Incompetent documentation
We've seen multiple cases where serious mistakes were made when drafting trust documentation:

These include:

e One trust deed had a section entitled “Exclusion of settlor and spouse”. This clause is usually
included to prevent the trust being settlor-interested. However you somehow duplicated the text of
the applicable law clause into this clause. The trust therefore became settlor-interested..

e We've also seen a case where you drafted a trust deed with the trustee/beneficiary stated as the
settlor.

e Your “Fund A’ and “Fund B’” trusts, attempting to avoid IHT trust charges, are incompetently
drafted. When is the valuation tested? Is it tested daily? Annually? Upon a specific triggering
event? The deed is entirely silent. How is a valuation determined? Again - nothing.

It appears that you are preparing/drafting trusts over land. If so then, as you are not solicitors, this is a
criminal offence.

If you have any comments I'd be grateful if you could provide them by 5pm on Tuesday. Please note
that we are committed to transparency and are likely to publish your response.

Yours faithfully,

Dan Neidle

TAX
POLICY
ASSOCIATES

Dan Neidle
Tax Policy Associates Ltd
dan@taxpolicy. org.uk | taxpolicy. rg. uk

x 14

And then, after MP Estate Planning acknowledged receipt:

Dan Neidle
Re: Request for comment - report on MP Estate Planning
To: fltke Fue

Dear Mr Pugh,

Thank you for your email.

One other point where I’d be grateful for comment: your
previous business failed with £1.7m owed to HMRC. We’re
trying to understand how a business of that size could have so
large a liability.

Yours sincerely,

Dan Neidle

| Dan Neidle

Here’s their response. It reads like a press release, and doesn’t answer a single substantive point (other than the unconvincing “editing” explanation for their May 2023 video, as noted above).

whe MP ESTATE
“PLANNING UK

Dan Neidle

Tax Policy Associates Ltd
124 City Road,

London

EC1V 2NX

AND BY EMAIL TO: dan@taxpolicy.org.uk
10 March 2026
Dear Mr Neidle,

Thank you for your email of 5 March and for providing MP Estate Planning UK with the
opportunity to comment prior to publication of your forthcoming report.

We take scrutiny of the estate planning sector seriously and welcome the opportunity to
respond openly to the points you have raised.

MP Estate Planning UK has been supporting families with estate planning services for
several years, working with clients across the Southwest and throughout the UK. During
that time, we have built a strong record of client satisfaction, reflected in extensive
client feedback, including a Trustpilot rating of 4.4 and a Google review score of 4.9.

Our advisers act as the primary point of contact for clients, providing accessible
guidance on estate planning matters. Where a client’s circumstances require specialist
or regulated advice, we refer or signpost to appropriately qualified external
professionals. These may include solicitors, chartered tax advisers, independent
financial advisers and other regulated professionals depending on the nature of the
issue. This approach ensures that clients receive the appropriate expertise where
specialist advice is required.

Collectively, our team brings significant experience across estate planning and related
services. We operate an ongoing programme of professional development and training,
and we remain committed to maintaining high standards of professional conduct and
client care.

As part of our commitment to public education, our founder, Mike Pugh, produces
regular online content discussing estate planning topics that are commonly raised by
clients. These videos are intended to provide general information only and do not
constitute regulated financial or legal advice. Viewers are encouraged to seek tailored
professional advice appropriate to their own circumstances, and we routinely signpost
individuals to qualified professionals where necessary.

Wills # Trusts # LPAs # Probate

MP Estate Planning UK, Leigh Court, Pill Road, Abbots Leigh, Bristol BS8 3RA on? 4401555
MP Estate Planning UK Limited. Registered in England and Wales No. 14774020 :
Registered Office: Leigh Court, Pill Road, Abbots Leigh, Bristol BS8 3RA mpestateplanning.uk
why MP ESTATE
“PLANNING UK

We reject the suggestion that our work is misleading or uninformed. Estate planning,
particularly where trusts and inheritance tax planning are concerned, involves complex
legislation and areas of interpretation which are debated among practitioners. Our work
is undertaken in good faith with reference to the statutory framework governing trusts
and inheritance tax in England and Wales, together with established professional
commentary and practice in the estate planning sector.

Where any communication has the potential to cause misunderstanding, we take
responsibility for clarifying it. For example, one video referenced in your email dated
from May 2023 was removed from our platforms once we identified that the editing of
the short-form clip conveyed the point poorly and could lead to confusion.

More broadly, if there are specific legal authorities, statutory interpretations or HMRC
guidance that you believe demonstrate that particular planning structures are
ineffective or non-compliant, we would welcome the opportunity to review them.
Constructive dialogue on complex areas of law and taxation is important for the
development of good practice across the sector.

MP Estate Planning UK remains committed to operating responsibly, transparently and
in the best interests of our clients. We welcome informed scrutiny and are always
prepared to clarify our approach where questions arise.

Mike Pugh
MP Estate Planning UK

Wills # Trusts # LPAs # Probate

MP Estate Planning UK, Leigh Court, Pill Road, Abbots Leigh, Bristol BS8 3RA ON? 440 1555
MP Estate Planning UK Limited, Registered in England and Wales No. 14774020 .
Registered Office: Leigh Court, Pill Road, Abbots Leigh, Bristol BS6 JRA. mpestateplanning.uk

This is our response to that letter:

Dan Neidle~ ©
Re: Request for comment - report on MP Estate Planning
To: °°- +

Dear Mr Pugh,

Thank you for your email and the attached statement.

We wrote to you on 5 March and asked for any comments by 5pm on Tuesday. That gave you five days to respond.
Your statement does not address a number of the straightforward factual points raised in our email, including:

* why your website claims you work "in conjunction with" the Chartered Insurance Institute when the Cll say you have no association
with them

* why your materials repeatedly use US tax and trust terminology which has no meaning in UK law

* why you claim an association with James Kessler KC which he says does not exist

* why your videos refer to a "head of legal" who does not appear to exist

| am also concerned by your response regarding the May 2023 video.

You said in the video: “Let’s say you bought a home many years ago for £300,000, and now it’s worth £900,000. If you transfer or
dispose of the property you could trigger a capital gains tax charge”. This statement ignores the existence of the main residence
relief.

Then: “There are workarounds. For example, if the children move in with you then you may be able to transfer the property to them
without triggering the capital gains tax as long as you continue to qualify for the main residence relief’. This makes no sense.
Suddenly the main residence relief exists, but is connected with whether the children are living there?

Your claim that this was an editing error is not credible. The statements above are complete propositions expressed in full
sentences; they are not the product of an ambiguous edit.

| hope that, on reflection, you will accept that this was not the result of an editing error and will provide an honest explanation before
we go to press. If we do not hear from you, we will note in our report that this question was put to you and that no explanation was
provided.

We will be publishing our report tomorrow. We will include your statement in full. If you identify any errors of fact or law in our report
we will correct them promptly.

Yours sincerely,

Dan Neidle

We received a further reply – this time with responses to the “non-existent head of legal” and “use of US terminology” points that we regard as deliberately misleading:

Mike Pugh Lot ag
Re: Request for comment - report on MP Estate Planning
To: Dan Neidle

Dear Mr Neidle,

Thank you for your further email and for setting out the additional points you would like
addressed.

We have always believed that scrutiny is part of maintaining standards in an industry where
clients are placing a great deal of trust in the advice they receive.

Taking your points in turn:
References to the Chartered Insurance Institute

Some of our colleagues are members or graduates of the Chartered Insurance Institute
include Mr Zubair Abad.

There is no formal relationship with the Institute itself. We have amended the wording on our
website to more accurately reflect this.

Use of US terminology

You have identified instances where legacy or internationally sourced educational material
has used terminology more commonly associated with US trust law.

Where those terms have appeared on UK-facing pages, we agree that they are not the
correct terminology for English law and we are reviewing and updating older content
accordingly.

Reference to James Kessler KC

We do not have, and have never had, a formal professional relationship with Mr Kessler. We
hold him in the utmost respect as a leading authority in this area of law. Any information or
materials that may previously have implied a formal relationship, whether professionally or
otherwise, have now been removed in their entirety. It has never been our intention to
suggest that there was any direct relationship with him personally.
Reference to a “head of legal”

You raise the point about references in video material to a “head of legal’. This refers to the
involvement of legally trained professionals within the wider advisory ecosystem we work
with, rather than suggesting a formal internal role that does not exist.

The May 2023 video

In the case of the video you referenced, we accept that the content was both poorly scripted
and poorly edited. Once this was raised with us, we immediately took down the video.

| remain personally grateful for the assistance and feedback from professionals across the
industry who continue to help refine the way these topics are explained. We remain
committed to operating transparently and responsibly.

Where legitimate errors are identified, we correct them. Where interpretations differ, we
believe the appropriate approach is to examine the statutory framework and engage in
constructive and transparent debate around its interpretation.

Thank you again for engaging with us on these matters.

Yours sincerely,
Mike Pugh
MP Estate Planning UK

Kb. jive fie

whe MP ESTATE
“PLANNING UK’

Every Home In A Trust

0117 440 1555
Business West, Leigh Court,
Pill Road, Abbots Leigh BS8 3RA

We gave then Mike Pugh a final chance to respond substantively:

Dan Neidle
Re: Request for comment - report on MP Estate Planning
To: Mike Pugt

Dear Mr Pugh,
I’m afraid | have to conclude you are trying to mislead me.

Your videos referring to “revocable trusts” were not aimed at US audiences, because they refer
to inheritance tax. They were aimed at UK audiences. The only plausible explanation is that
you have a poor understanding of English law and UK tax.

You had dozens of pages on your website specifically referring to revocable trusts in the
context of the UK (I see you've tried to delete them). You also had multiple pages (recently
deleted) telling grieving relatives that they needed to apply to probate court to obtain UK
probate. This was deeply irresponsible. What were you thinking?

You aren’t able to explain why you made multiple references to a “head of legal”, and you
instead duck the question. | have to conclude it was a lie.

You first said the 2023 video had been an editing error. Then you blamed the script. Now it's a
“genuine mistake’. The point is: nobody with any knowledge of capital gains tax would make
that mistake.

| still await an explanation of the hopeless legal and tax claims you make in your promotional
material. l’ve no idea who the “highly regarded TEP solicitor” is, and | have to say |’m not
confident they exist - we haven’t been able to identify an external firm that you use. If you think
that’s wrong, please name the firm.
The trust deeds we’ve seen appear to have been drafted by ME Estate Planning and not an
external firm. That is itself a criminal offence.

| hope on reflection you will realise that you are way out of your depth and this has gone very
wrong. The responsible thing to do would be for you to pause the business, take down the
website and videos, review all of your business practices and past advice, and commit that only
qualified personnel will provide estate and trust advice in future.

Will you do this?

| fear that you will not. We plan to publish tomorrow. We will be saying that you are misselling
trusts to the elderly, your advertising is misleading, your website is Al generated nonsense, you
lied about your legal personnel, appear to have no expertise, and are engaging in reserved
legal activities without authorisation.

Yours sincerely,

Dan Neidle

Dan Neidle

TAX Tax Policy Associates Ltd
POLICY dan@taxpolicy.org.uk | taxpolicy.org.uk
rv ASSOCIATES Broxpoliy.org.uk | taxpoliy. org
Arnorepr company lime by quaramee ne 140153873
Repoered fie, "24 oly Reva cede EC ty 2NX

Pugh told us we’d receive a response to our technical questions: we never did. Nor did we receive an explanation as to why his previous small business went bust owing HMRC £1.7m.


Text and images © MP Estate Planning (UK) Ltd republished here for purposes of criticism and review, and in the public interest.

Many thanks to B, S1, K and I for telling us about their experiences with MP Estate Planning (UK) Ltd.

This was a particularly complex investigation which we couldn’t have undertaken without a large team of lawyers and tax specialists, all acting pro bono. This article was written thanks to:

  • Inheritance tax: SH for her invaluable initial analysis, then further work from P and M and additional review from J2 and SH (again).
  • Other direct tax: D and Rowan Morrow-McDade (who found the 2023 video with the nonsensical claims about main residence relief)
  • Stamp duty land tax: J1 and Rowan, again.
  • Real retate finance: P
  • Care Act: V and Y.
  • Family law: T.
  • Insolvency law: A and I with additional review from C.
  • Corporate structure and business history: M.
  • Additional research and data: business intelligence provider Tech City Labs.

Plus numerous other practitioners who read through late drafts.

We usually can’t name our contributors, partly because it could be professionally awkward for their current employer, and partly because of concerns about retaliatory legal action.

Footnotes

  1. Full name MP Estate Planning (UK) Ltd. It shouldn’t be confused with MP Estates, a reputable estate agent. ↩︎

  2. For MP Estate Planning personnel to actually commit fraud would require them to know that they were making false claims and to be acting dishonestly; we don’t know if either is the case. It is plausible they are just reckless. ↩︎

  3. We are reasonably sure it is the same individual. The Daniel James Irwin who was a director of Safe Hands had a date of birth May 1990. Daniel James Irwin, date of birth June 1990, is also a director of a previous Maplebrook trust entity. He has two LinkedIn accounts, neither of which are updated, and neither of which show his time at Safe Hands. ↩︎

  4. It is reasonably clear that an untrue representation was made by Mr Pugh with the intention of making a gain, and that he knew it was untrue. The crucial legal question to determine whether an offence was committed is whether Mr Pugh was “dishonest”. Under English law, this means asking whether his conduct was dishonest by the standards of ordinary decent people (regardless of whether the individuals themselves believed at the time that they were being dishonest). The subjective element of the test for dishonesty (see Ghosh (1982)) was removed by Ivey [2017] for civil cases, and that decision was confirmed to apply to criminal cases in Barton [2020]. The fact that a defendant might plead he or she was acting in line with what others were doing, and therefore did not believe it to be dishonest, is no longer relevant if the jury finds they knew what they were doing and it was objectively dishonest. The leading textbook of criminal law and practice, Archbold, states: “In most cases the jury will need no further direction than the short two-limb test in Barton “(a) what was the defendant’s actual state of knowledge or belief as to the facts and (b) was his conduct dishonest by the standards of ordinary decent people?”. ↩︎

  5. We don’t think any real person would write “Best will writing service and lasting power of attorney in Bristol, UK” or “MP Estate Planning offers great services and customer care when it comes to estate planning, lasting power of attorney and will planning in Bristol”. ↩︎

  6. We refer to English law because our usual team does not have expertise in Scottish law or the law of Northern Ireland; but we are reasonably confident that Pugh’s comments are equally inapplicable to Scottish and Northern Irish law. ↩︎

  7. There would be stamp duty if the children took over the mortgage – but MP Estate Planning appears to leave the mortgage where it is. ↩︎

  8. The website also has about 800 “doorway pages” – pages identical apart from the location, for example “estate planning in Stevenage” – you can see the complete list here. This is a well-known strategy to capture Google searches which is widely seen as abusive and misleading (“Based on our 18 years of experience providing inheritance tax advice in London…” or “Do You Need 24 Hour Emergency Estate Planning Services in Litton?“). The figures in the main text for the number of articles and words exclude these “doorway pages”. ↩︎

  9. Tech City Labs kindly provided us with the report pro bono and has authorised us to publish it here. ↩︎

  10. The trusts discussed here are discretionary trusts and settlements – the kinds of trust MP Estate Planning sells. The most common kind of trust is a “bare trust” or nominee arrangement – those arise all the time by operation of law in many ordinary personal and business contexts, and don’t normally have tax consequences. ↩︎

  11. The lifetime rate of IHT is 20% but in practice, and especially where the trustees only hold assets not cash, the effective rate is normally “grossed up” to 25% as it’s the donor rather than the trustees that pay the tax.  ↩︎

  12. Plus an exit charge on any part-ten year period when/if the trust comes to an end. ↩︎

  13. With complex rules that often, but not always, avoid double taxation. ↩︎

  14. As we say in the introduction, for MP Estate Planning personnel to actually commit fraud would require them to know that they were making false claims and to be acting dishonestly; we don’t know if either is the case. ↩︎

  15. After seven years another £325k nil rate band becomes available, but for the first seven years this structure is all downside. ↩︎

  16. When is the valuation tested? Is it tested daily? Annually? Upon a specific triggering event? The deed is entirely silent. How is a valuation determined? Again – nothing. And how does “Fund B” Work? It’s not clear it can be a “bare trust” because under Saunders v Vautier, the beneficiary (the Settlor) would be entitled to call for the trust property – but here that can’t happen because the trustees are holding for both the bare trust and the discretionary trust. However the intention is clear enough that the trust lawyers we spoke to thought that the trust would likely be given effect, notwithstanding the very unclear mechanics. ↩︎

  17. Ordinarily, transferring assets into a relevant property trust allows for capital gains tax to be held over under section 260 of the Taxation of Chargeable Gains Act 1992. However, section 169F specifically denies this relief for settlor-interested trusts. ↩︎

  18. A gift to a trust is not usually subject to stamp duty land tax, because there is no consideration. However this is not a gift – the parent/settlor is getting something back – the right to receive all value over £325k. We’ve considered whether that gives rise to an SDLT charge, either on day one or subsequently – our conclusion is that it probably doesn’t (but it’s a complex question and we haven’t undertaken a full analysis). ↩︎

  19. Patrick Soares says he believes the section applies if a child “treats [the property] has his home, is physically present there most weekends and for some holidays, has an earmarked bedroom and study, keeps some of his possessions there and has the keys to come and go as he pleases, and he is not just a guest or temporary visitor”. Emma Chamberlain takes a slightly more cautious view, saying that there must be substantive occupation even if not as a main home. These seem defensible readings to us – “occupy” clearly means actual physical presence but it doesn’t necessarily mean full time occupation. There is some risk in the Soares/Chamberlain approach, and we can’t exclude HMRC challenging such an arrangement on the basis that, for two people to “occupy” a property, their presence must be of similar (but not identical) intensity (which seems to have been the intention of the Government that enacted the rule). Other advisers take a more cautious view. ↩︎

  20. There is no caselaw on this point. There are, however, non-tax authorities on the meaning of “occupy”; they illustrate the (obvious) point that it requires an actual presence, not just the potential for a presence. In this case we feel the purpose of the taxing statute (as elucidated by the Dawn Primarolo statement) puts the point beyond reasonable doubt. ↩︎

  21. The Soares and Chamberlain articles have been widely read, and their approach has been adapted by some firms into a much less rigorous approach that we suspect Soares and Chamberlain would disagree with. For example, Countrywide says “The test is likely to be satisfied where, for instance, there is a gift of a share of the main residence to a child who visits the property on a regular basis, is able to come and go as they please, have their own key and leaves their possessions at the property. There does of course need to be more than mere storage of items at the property and so an occupier having their own bedroom and being able to come and go as they please would certainly make the test easier to satisfy”. This may be over-reading HMRC guidance on occupation in the context of the pre-owned assets rules – HMRC has an obvious incentive to give the term a wide meaning here, but HMRC guidance is not legislation and in practice cannot be relied upon by taxpayers. ↩︎

  22. There are other more sophisticated structures involving s102B, and it has been suggested the GAAR could apply to them (see page 20 of this expanded version of the Patrick Soares article), but we don’t think the GAAR would be necessary to the MP Estate Planning structure. ↩︎

  23. Even if MP Estate Planning’s “loopholes” did work to avoid the gift with reservation rules (they don’t), there is a separate anti-avoidance regime that can still impose an ongoing tax charge: the pre-owned assets tax (POAT). POAT was introduced to counter arrangements where someone successfully removes an asset (typically a home) from their estate for inheritance tax purposes, but continues to enjoy it. It is a standalone income tax charge on the benefit of continued occupation/use of an asset you previously owned or funded. The rules are complex but, given MP Estate Planning’s trusts fail to avoid the gift with reservation rules, we won’t go into them further. ↩︎

  24. Sch 20 para 6(1)(a) says the donor’s continued “actual occupation of the land … shall be disregarded if it is for full consideration in money or money’s worth”. This is the statutory basis for the “pay market rent” approach. ↩︎

  25. Ingram involved a “lease carve‑out” scheme: the homeowner created and kept a proprietary lease (so they had a real property right to stay), and only then gave away the freehold. Later legislation severely restricted that approach. Subsequent attempts to find similar work-arounds have failed. ↩︎

  26. We think it probably isn’t disclosable under DOTAS because it is in sense “too simple”: there’s nothing contrived about it. It is however possible that the “premium fee” hallmark applies as a factual matter. ↩︎

  27. Although less than three years may trigger a charge under the unrelated provision in paragraph 17A Schedule 15 Finance Act 2003. ↩︎

  28. There seems to be a common view amongst some unregulated advisers that it’s safe to form a partnership, wait three years, and then incorporate. There is no such limitation on section 75A in the legislation or any HMRC guidance – the sole question is whether partnership and incorporation are, together, “scheme transactions”. Where a partnership is established as a step towards incorporation, then in our view there probably would be “scheme transactions”. That is particularly the case when there is no rationale other than tax to establish the partnership (and it’s hard to see what other rationale there could be). ↩︎

  29. The courts have found trusts to be “other financial resources” in numerous cases of “real” trusts where the settlor influences the trustees, but does not have complete control. The test in Charman v. Charman [2006] 1 WLR 1053 is “whether, if the husband were to request [the trustee]to advance the whole (or part) of the capital of the trust to him, the trustee would be likely to do so”. ↩︎

  30. This is all assuming the trust was established well before the parties became aware that there could be a divorce. If it wasn’t, the question is whether the trust was created “with an intention to defeat” the spouse’s financial claims. In such cases, the court could make an order to set it aside under section 37 of the Matrimonial Causes Act. There is a rebuttable presumption that the trust was created with such an intention if it was created less than three years before the date of the court application. ↩︎

  31. Such an improper purpose will exist even if there are other purposes, such as tax avoidance. ↩︎

  32. The Lemos judgment provides a useful example of how the courts apply section 423 in practice. ↩︎

  33. In addition to incorrectly citing the Insolvency Act, Pugh also incorrectly claims this is a “criminal offense”. In the UK, transferring assets to put them beyond the reach of creditors is typically a civil matter leading to the transaction being set aside under section 423 of the Insolvency Act 1986. While there are some specific bankruptcy offences if a person is already bankrupt, merely putting assets into a trust to avoid future creditors is legally ineffective, but not generally a criminal offence in itself. ↩︎

  34. See also the Local Government and Social Care Ombudsman’s approach to deprivation of capital cases. ↩︎

  35. As is often the case with tax planning, this means that MP Estate Planning’s own marketing undermines the effectiveness of their product. Someone who obtains advice from MP Estate Planning and then creates a trust could well be in a worse position than someone who creates a trust themselves, or using some other adviser who doesn’t use care home fees as a selling point. ↩︎

  36. Another way of putting the point is to distinguish two ways in which someone’s care needs might be foreseen. First, one may have a case where someone is medically unwell or infirm and for that reason it is foreseeable they may have care needs. Second, one may have a case where someone has been told “put your assets in a trust so that if you have care needs the local authority can’t touch them”; such a person has in fact foreseen that they might have care needs, even in the absence of any medical- or health-related reason to think that they will. ↩︎

  37. A further point is that section 70 of the Care Act 2014 gives the authority the power to go after the recipient of the assets personally to make up the difference. We’re not aware of section 70 having been used against a trustee, but it seems to us in principle that it could be. ↩︎

  38. See the table at para 11.1, section C in the guidance from Kent County Council. ↩︎

  39. For the reasons set out in our technical analysis above, the trust likely falls to be a settlor interested trust anyway, but the drafting means the planning would fail regardless. ↩︎

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