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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Letters of offer: consideration

In English law, a contract normally requires consideration to make it binding - thetaxpayer’s offer is matched by HMRCs agreement not to take further proceedings.Scottish contract law does not have this requirement, but it is still considered desirableto set out the consideration in a Scottish offer.

Where extra time is being allowed for payment, and an additional ‘interest’charge (IHTM36253) is being made the words ‘and the timegranted’ should be added after ‘hereby offer in respect of the (duties,)(interest) (and) penalties’.