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HMRC internal manual

Inheritance Tax Manual

Negotiating a settlement: examples of negotiating situations

These are some of the situations where a negotiated settlement may be appropriate

  • valuing an asset which is not dealt with by a specialist valuer
  • the allowable deduction in respect of a debt that is claimed to be due to the relative of the deceased (IHTM28321)
  • what constitutes reasonable funeral expenses (IHTM10371)
  • the valuation of any lifetime transfer resulting from a guarantee debt (IHTM28356)
  • the amount allowable in respect of a guarantee debt where full reimbursement is not expected (IHTM28355)
  • the deduction allowed for foreign administration expenses (IHTM27050) under IHTA84/S173 where the 5% limit does not apply
  • what the deceased provided in respect of a joint account (IHTM15000)
  • the extent to which withdrawals from a joint account (IHTM15000) give rise to lifetime transfers
  • the availability of business relief on bank or building society accounts (IHTM25341)
  • the discount for occupation of the deceased’s property (IHTM23002)
  • the extent to which a transfer was intended to confer gratuitous benefit
  • the extent to which a normal expenditure out of income (IHTM14231) claim is allowable
  • the application of equitable estoppel
  • the value of a future (IHTM28110) or contingent liability (IHTM28070) not dealt with by the Actuarial Team
  • any case where the facts are uncertain and are impossible to establish.

This list is not exhaustive.