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HMRC internal manual

Inheritance Tax Manual

Certificates of full disclosure and corrective accounts: issuing a certificate or corrective account

There are statements (IHTM09531+) that explain the significance of the corrective account or certificate of full disclosure when they are issued following the discovery of an omission or an undervaluation. A separate statement is available where a corrective account is required but the statement for certificates is on the reverse of the certificate itself. Where possible the statement and corrective account (form C4) (IHTM10011) or certificate should be handed over to the taxpayer personally. This gives you the opportunity to emphasise the importance of the corrective account or certificate and answer any questions that the taxpayer might have about it. You should invite the taxpayer to take the certificate or corrective account away rather than sign it there and then. This allows the taxpayer to consider it and discuss its implications with any professional advisor acting. You should record the issue in the notes of the interview.

If you do not issue the statement and corrective account or certificate at an interview but send it to an agent, you should ask the agent to make sure that the taxpayer reads the statement and the corrective account declaration or the statement on the reverse of the certificate. They should also be aware of the significance of the certificate before signing it. You should make a similar request to the taxpayer if you send the documents direct to him or her.

Often the certificate will have to be tailored to the specific circumstances and if you need to issue a certificate you should send your file, with a brief explanation of the circumstances, to the penalties or liaison portfolio holders, who will let you have the appropriate document.