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HMRC internal manual

Complaint Handling Guidance

From:
HM Revenue & Customs
Published:
12 April 2016
Updated:
8 October 2026 - See all updates

CHG875 - Dealing with complaints: Third Party authority for deceased customer complaints

Any authority held for a customer automatically ceases when that customer dies.

This includes:

  • Agent authorisations
  • Third-party authorities
  • Forms of consent previously given by the customer
  • Any other authority that relied on the customer's ongoing consent

After death:

  • Previous authority must not be relied upon.
  • Anyone wishing to act on behalf of the deceased person's estate must provide new formal authority.
  • Evidence of their status (for example, executor, administrator, or personal representative) should be obtained before discussing the deceased person's affairs.

·       Important: If someone contacts us about the affairs of a deceased customer and there is no authority in place, you should still provide any general help and guidance you can. However, you must not disclose any information that relates specifically to the deceased customer's affairs until appropriate authority has been established.

Recording Complaints Involving Deceased Customers

When recording a complaint involving a deceased customer, the complainant should be recorded as the person who has been affected by the issue. This is separate from the question of who has authority to act on behalf of the deceased person's estate.

Complaint Type

Record as Complainant

Record as Third Party

Complaint about the deceased person's tax affairs

Deceased person

Person reporting the issue

Complaint about the treatment of an individual

The individual who was poorly treated

Any representative raising the issue on behalf of the complainant (if applicable)

Complaint about Inheritance Tax*

Estate of [deceased customer's name]

Person acting for the estate (solicitor, personal applicant – whoever is making the complaint)

*For complaints about Inheritance Tax:

  • record the complaint as a ‘Business’ rather than an ‘Individual’

  • record the business name using a simple and clear description of the estate, for example “Estate of [deceased customer’s first and last name]”

  • every Inheritance Tax complaint should have an associated Third Party recorded such as a personal representative, executor, administrator or other authorised representative.

This approach ensures that complaints are recorded against the person affected by the issue, while maintaining the correct authority and representation requirements following the customer's death.