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HMRC internal manual

Inheritance Tax Manual

Certificates of full disclosure and corrective accounts: when to ask for a certificate or account

The right time to ask for the corrective account or certificate is when you believe that the taxpayers have supplied all the information they have about the estate or transfer and before you finally agree the amount of the total chargeable transfers.

A further suitable opportunity to obtain a corrective account or certificate arises immediately before you consider with the taxpayer how the case is to be settled. This will be either by way of informal calculations for the tax and interest and a negotiated contact settlement for any penalty or a negotiated contract settlement to cover tax, interest and penalties.

You should not seek a certificate of disclosure at the conclusion of an enquiry in whichyou find that nothing is demonstrably wrong with an account or no tax is payable following a failure to deliver an account.