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HMRC internal manual

Inheritance Tax Manual

Governance: review of high-yield cases

As part of our governance requirements we will conduct quality checks to review our highest-yielding cases. We will use this review to help our learning and to consider the Compliance issues that arise on these cases.

By reviewing these cases we will be able to identify

  • Particular areas where risk assessment and research work has been productive
  • Examples of good quality compliance work and the techniques that are useful in reaching successful conclusions
  • Issues where the technical input was important to the final outcome and where we should ask for the same input to identify issues that might apply in other cases

We will also be able to check that the correct yield has been claimed

The Trusts and Estates Compliance Strategy and Delivery Team (CSDT) will review the cases that meet the criteria to be considered as high-yielding cases. They will give recognition and feedback on any useful issues that arise on a case by case basis. If they identify any common issues we will use this information in our case selection and case direction processes.


Cases will be considered to be ‘high-yielding’ where the combined intervention yield for tax, interest and penalties is equal to or more than

  • £150,000 for lifetime and settlement cases
  • £400,000 for Compliance and Litigation cases

If a case you are working meets these criteria you should refer it to the CSDT as soon as possible after you have closed the ERS record or issued the Unit3 or Unit4

If a case is missed or not sent at this time it will be identified on management information lists.