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HMRC internal manual

Inheritance Tax Manual

Determination of questions on previous view of the law: amendments after the change of practice

It may happen that, after payment has been regarded as satisfying a liability for tax, the claim is shown by a legal decision or a change of practice to have been excessive or non-existent. If in such circumstances any question should arise of assessing additional tax on the property affected, by reason of the disclosure of other property or otherwise, you should refer the case via your manager to the Assistant Director.

IHTA84/S255 can apply only where there has been payment and acceptance of tax. It does not prevent the raising of a claim where:

  • facts which were not disclosed subsequently come to light and
  • tax which would not have been claimed on the basis of such facts under the official practice at the date of the transfer has been shown by a subsequent judicial decision to be properly eligible.