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HMRC internal manual

Inheritance Tax Manual

Dealing with taxpayer's replies: claims that excess monetary deposits prevent a penalty being sought

Excessive deposits might be made with or before delivery of an account but the taxpayer or agent makes no reference to additional assets or under valuations when the account is submitted. If it is subsequently discovered that the account is incorrect as a result of the taxpayer’s negligence then a penalty should be sought. The only link between penalties and tax is to be able to determine the maximum extent of any penalty.

The ‘offence’ arises at the time the account is submitted and whether or not additional money has been placed on deposit over and above that calculated as due on the original account has no bearing on the matter.