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HMRC internal manual

Inheritance Tax Manual

Communications: Handling of complaints/compliments: delays and mistakes

If a complainant does not ask for financial redress (IHTM02247), but

  • we have made a mistake, or
  • caused an unreasonable delay

you should think about whether some form of financial redress is due. If you think it might be you should refer the case to your manager, but do not suggest to the complainant at this stage that costs may be due.

If the manager thinks costs or consolatory payments may be due, they should consult the Customer Service Manager in Ferrers House.

You should never attempt to trade off costs or interest remission against tax.


All delays are regrettable and may require an apology and an explanation. But not every delay is unreasonable. Only when we accept that the delay is unreasonable will we consider financial redress.

  • We will make financial redress where costs have arisen as a direct result of unreasonable delay we have caused.
  • Unreasonable delay applies to the way we have dealt with a customer’s affairs. For example, delays in dealing with post, issuing a form IHT421 or making a tax repayment might be unreasonable.
  • Our administrative processes take time. The normal amount of time taken to do such work would not count as unreasonable delay, although the customer may feel that is the case.
  • If we are aware that a step in our process that will take some time to complete (for example a DV referral, or a request for technical or litigation advice) it is reasonable that we should explain this to the customer and keep them informed throughout the process. We should also make them aware of any additional delays.
  • The decision as to whether a delay is reasonable or not can be very subjective. In order to reach a decision, you must take into account all the circumstances of the particular case.

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Redress may be appropriate in any case where we have made a mistake. We need to look at mistakes from the customer’s point of view and not assume that because we regard the mistake as a trivial one, it had no impact on the customer.

Making an objective judgement can be difficult but it may be useful to stand back and consider how you feel when you are on the receiving end of a mistake. Surveys confirm that when people complain they want to have things put right and to receive an apology. They do not automatically think of financial redress but are more inclined to do so when the mistake has affected them particularly badly, is repeated, or their complaints about it are ignored.

It is important to distinguish between cases where we have made a mistake and those where we have not. Some examples of circumstances which we might not regard as our mistake are:

  • Processing inaccuracies where the customer’s entries on the HMRC Account are incomplete or not clear.
  • Information about a customer’s affairs are no longer available because the records have been correctly destroyed in accordance with our internal instructions.
  • Failure to make a repayment out to the customer in the names or names they wanted because we do not have the authorisation to do so.

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Poor management of customers’ records

Sometimes we mislay records. So, we may need to ask customers and their agents for copies of letters and documents, which might lead to a claim for costs. Similarly, we sometimes cause unnecessary costs by duplicating our records.