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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Enquiries: what constitutes an enquiry?

If you work in Compliance and are writing to the taxpayers because you think something is incorrect or requires fuller explanation, you are questioning the account. You should open an enquiry. Examples of when you need to open an enquiry include

  • seeking the delivery of a late account and then, challenging that account, if necessary,
  • asking a taxpayer for additional information about an area of risk identified in the account or an Instrument of Variation (IHTM35010) (IOV),
  • disputing the taxpayers interpretation of the facts, the value of an asset, liabilities claimed, exemptions or reliefs claimed or the effect of an IOV,
  • asking why items have been omitted or understated in accounts, and
  • challenging negligent conduct and seeking penalties

Once we have decided to challenge an account, or aspects of it, all areas we decide to examine on that account will form part of the enquiry. This includes, for example, amendments identified by FACET share checks that in themselves would not amount to an enquiry. Although any adjustments that FACET have assessed pre-grant should not be recorded as part of your enquiry work

We often find out about understatements of values or omissions from an account because the parties choose to tell us or as a result of non-enquiry work (IHTM08012). Where these understatements or omissions are over certain limits, we will risk assess the case again. If the risk assessor feels that the person(s) responsible may have been negligent they will refer the case to Compliance. You should open an enquiry to investigate the possibility of negligence (IHTM36000) in these and any other areas of the account.