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HMRC internal manual

Inheritance Tax Manual

Settling the penalty: delay in accepting offer

Once made, an offer that is neither withdrawn nor rejected remains open for acceptance for a reasonable time. In the case of a penalty settlement, 6 months is considered a reasonable time. If an offer is not accepted within 6 months of the date of the letter of offer (IHTM36331) the taxpayer should be asked to confirm in writing whether the offer should still go forward for acceptance.

Where the letter has to be sent to Tax Administration, Litigation and Advice (TALA) (IHTM36361) you should ensure that it is submitted in good time for any acceptance letter (IHTM36267) to be issued within the 6 month period. If the submission is made within a month of the end of the 6-month period you should mark the case prominently for urgent attention.

Once an offer has been made any attempt to negotiate further, or to re-open negotiations, whether following instructions from Tax Administration, Litigation and Advice (TALA) or otherwise, could in law amount to the rejection of the offer. If following further negotiations you are unable to secure a better offer and you propose to accept (or recommend acceptance of) the original offer, you should normally ask the taxpayers if they are content for the original offer to go forward for acceptance. The exception to this rule is when you have been advised to the contrary by Tax Administration, Litigation and Advice (TALA).