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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Failure to deliver an account: when can you seek a penalty?

You may consider seeking a penalty where following a chargeable event a taxpayer fails to deliver an account or corrective account that is due under IHTA84/S216 or IHTA/S217, IHTA84/S245 (1). In general the penalty provisions for failure to deliver an account are used in important cases only. But if

  • the time limit (IHTM10803) for delivering the account has passed
  • an account has not yet been received, and
  • you have evidence to suggest that there is tax due

you should refer the matter to Litigation, through your SO manager, for advice on what action should be taken.

This is a separate penalty provision from that which applies (also under IHTA84/S245) to accounts delivered late (IHTM36021).

You should not seek a penalty for a corrective account that is delivered late if we have allowed the customer to save up their amendments (IHTM31023)