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HMRC internal manual

Inheritance Tax Manual

Instalment offers: payments exceeding 2 years

Although the general position is that taxpayers should not escape the consequences of their failure it is not the Board’s policy to bind taxpayers to a contract that would involve causing them severe hardship over long periods of time. It should only be in exceptional cases where payments should extend over a period of longer than 5 years. If you feel that you have such a case, where it becomes apparent that a standard offer cannot be met within a 5 year period, you should refer the case to your SO manager who will consult with the Penalty Portfolio Holder and Tax Administration, Litigation and Advice (TALA) (IHTM36361) as necessary.

Offers of payment over more than 2 years also need to be referred for acceptance when the letter of offer is returned (IHTM36263).