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HMRC internal manual

Inheritance Tax Manual

Accountability: introduction

The rules on accountability are found in IHTA84/S216.

In general, the accountable person is someone who is liable for any tax (IHTM30011) on the assets concerned. But not all those who are liable for tax are accountable and, very exceptionally, a person who is not liable may be required to deliver an account.

The relationship between accountability and liability was discussed by Walton J in CIR v Stype Trustees (Jersey) Ltd [1985] STC 394, CTT Cases No 27.

Different rules may apply in some circumstances to

  • transfers on death (IHTM10811)
  • transfers in respect of a qualifying interest in possession in settled property (IHTM10831)
  • lifetime transfers that are chargeable when made (IHTM10822)
  • failed potentially exempt transfers (PETs) (IHTM10821)
  • gifts with reservation (GWRs) (IHTM10824)
  • relevant property settlements (IHTM10836).