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HMRC internal manual

Inheritance Tax Manual

Reopening IHT liabilities: introduction

Notwithstanding any misleading advice or other official error, you ought to pursue underpaid tax and interest unless there is a statutory bar to recovery.  Nevertheless in conformity with HMRC guidelines you should first consider the possibility of remission (IHTM30501) in the following exceptional situations.

  • It is claimed that a taxpayer has relied on misleading advice or assurance, whether given by a member of the office or in an official leaflet.
  • It is claimed that a taxpayer has acted to their financial detriment on the basis of an error made by the office.
  • A taxpayer has placed all the facts before us and we have failed to act within an appropriate time, and it is reasonable for the taxpayer to believe that their affairs were in order.