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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Failure to deliver an Instrument of Variation where additional tax payable: when can you seek a penalty?

You should consider seeking penalties under IHTA1984/s.245A where, following execution of an instrument of variation that results in additional tax, the ‘relevant persons’ (IHTA84/S142 (2A)) fail to meet the requirements of IHTA84/S218A to deliver a copy of the instrument within 6 months after the day on which the instrument is made.

While IHTA84/S218A also requires the relevant persons to notify us of the amount of additional tax that is due you should not seek a penalty where this requirement only is not met.