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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Certificates of full disclosure and corrective accounts: general

The instructions in this part of the manual apply when you are dealing with a full enquiry (IHTM29022) and either

  • you have discovered omissions from or undervaluations in an account as a result of your enquiries and negligence or fraud is involved, or
  • you have pursued an account where none was delivered within the statutory time limit (including no grant cases) or where an excepted estates grant was wrongly obtained and your enquiries show that tax is payable.

Before you finally agree the amount of the total chargeable transfers you should ask for a corrective account or certificate of full disclosure. Generally you should ask for a corrective account where the first bullet above applies and a certificate where the second bullet is in point.

There is no statutory authority for making such a request but, if an account is incorrect or not delivered, it is reasonable to ask for written assurance that all matters relevant to the investigation have been disclosed. This is so even though it may have been said in the course of correspondence or interview that all omissions have been rectified.

There are other circumstances that are not specifically related to a failure on the part of a taxpayer, where you may ask for a corrective account to be delivered.