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HMRC internal manual

Inheritance Tax Manual

Limitation of liability by lapse of time: property in the hands of purchasers

Property does not remain liable for any HMRC charge for Inheritance Tax against a purchaser (as defined in IHTA84/S272 and including a mortgagee) after the expiration of six years from the later of

  • the date on which the tax became due, and
  • the date on which a full and proper Account (IHTM10011) of the property was first delivered to the Board.

Heritable property in Scotland is not subject to the HMRC charge, but any property representing it after its disposal is subject to a charge (IHTA84/S237 (4)).