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HMRC internal manual

Inheritance Tax Manual

Reconsideration by taxpayers: bars to reopening value

There are several bars (IHTM30401) to the assessment of additional tax. Except in certain circumstances, we are not free to accept an offer to pay tax on a higher value if

  • any of those bars applies or
  • we have issued a formal notice of determination (IHTM37001) of the value of land.Where this is the position, if the taxpayers offer to pay tax on an increased value - whether by filing a corrective account (C4) (

IHTM10701), offering additional tax or otherwise, you should inform them that the value is settled so far as IHT is concerned and that no adjustment is required. If, nevertheless, the taxpayers persist, refer the case to your manager.