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HMRC internal manual

Inheritance Tax Manual

Compromise cases: unenforceable claims

If a claim is valid but cannot in the circumstances be enforced so that remission (IHTM30502) of tax and/or interest is a condition of settling the claim, the settlement requires the authority of the Debt Management & Banking.

Any case where the taxpayers indicate that a part payment should be accepted on the grounds that payment in full cannot be enforced should be referred immediately to the Team Leader (Debt Management)/Team Leader (Sco).