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HMRC internal manual

Inheritance Tax Manual

Grants on credit: statutory background

IHTA84/S226 (2) states that all Personal Representatives (PRs) (IHTM05012) who are liable for the tax by reason of IHTA84/S200 (1)(a) ‘shall, on delivery of their account pay all the tax for which they are liable’. IHTM30172 explains how to work out the amount that needs to be paid on delivery.

The Senior Court Act 1981/S109 requires that an account (IHTM10011) shows that:

  • the Inheritance Tax (IHT) payable on delivery of the account has been paid, or
  • no such tax is payable

before a grant can be issued or resealed in the UK.

Because of these statutory requirements it is only in the most exceptional circumstances that HMRC will allow a PR to postpone payment of all or part of the tax and interest due on delivery of an account.

We will not give a grant on credit simply because some difficulty in obtaining funds can be shown. We will consider one only where the difficulty envisaged is excessive or the cost is far greater than is customary or normal in the current borrowing conditions.

The various sources of funding available to the PRs are listed at IHTM05122.