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HMRC internal manual

Inheritance Tax Manual

Letters of Offer: instalment offers (general)

When you have agreed terms with the taxpayer, you should prepare a letter of offer basedon one of the standard letters (IHTM36351). You should carryout the same checks (IHTM36333) as for other letters of offerand also bear in mind the following

  • if the offer also includes tax and interest, ensure that the tax year of the death or chargeable event, the nature of the duty (inheritance tax) and the amount of the tax is shown on the form (on the back, if there is no room on the front)
  • the instalments should total precisely the amount of the offer - you may have to make one of the instalments a balancing figure (IHTM36346)
  • the amounts of the instalments should be precisely stated
  • the dates of payment should be precisely ascertainable - they should preferably be by reference to the date of the letter of acceptance (IHTM36267). (An instalment should not be expressed to be due by reference to the date of payment of an earlier instalment - payment of which might be delayed - though it can be expressed to be payable by reference to its due date. If you need to use specific dates, the earliest of those dates must be far enough ahead to allow time for the offer to be referred to your B2 manager and, if necessary, to Tax Administration, Litigation and Advice (TALA) (IHTM36361) via the Penalty Portfolio Holder, and accepted before the instalment becomes due.)

There are examples of how to express the instalment offers on the next page (IHTM36346).