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HMRC internal manual

Inheritance Tax Manual

Compromise cases: points of law

Where in a particular case the validity of a claim for tax or its extent is disputed by the taxpayers on a point of law, a lower figure than the full amount of the tax involved cannot be accepted by way of compromise except on the authority of the Litigation Team or Grade 6.

This does not apply to cases in which a compromise is reached on grounds other than a settlement of a disputed point of law (e.g. on a question of the market value of some property) or where - on the available evidence - there is a doubt as to the facts.