Adjustment of tax paid: underpayments
As a general rule, if too little tax has been paid, the additional tax is payable with interest. This is so even if the tax paid was that stated in a Notice of Determination (NOD) (IHTM37001) under IHTA84/S221. This general rule may be restricted or excluded by any of the following
- the instructions on reopening IHT liabilities (IHTM30411)
- the instructions on reconsideration of value (IHTM30421)
- where there is a change of view of the law or practice (IHTM30451)
- lapse of time (IHTM30461)
- a clearance certificate (IHTM40141) has been issued.
Where a transfer is reported after tax on a subsequent transfer has been settled, you need to consider IHTA84/S264.