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HMRC internal manual

Inheritance Tax Manual

Standard letters of offer: specimen form of offer involving penalties only, payable by instalments - England, Wales and Northern Ireland cases

Specimen form of offer involving penalties only, payable by instalments - England, Walesand Northern Ireland cases.

To The Commissioners of HMRC


Liability to penalties for the year to ……….. under the provisions of theInheritance Tax Act 1984 has been incurred by us as Personal Representatives of………………… deceased,


We the undersigned, (a) (Name) of (address), (b) (Name) of (address) and (c) (Name) of(address) as Personal Representatives of …………. deceased hereby offerin consideration of no proceedings being taken against us in respect of the said penaltiesto pay to the Commissioners of HMRC the sum of £…….. (“the said sum”)being £…….. in respect of the said penalties, together with£……….. in respect of the time granted.

If this offer is accepted by the Commissioners of HMRC so that a binding agreement isconstituted, we agree that it shall be subject to the following terms.

  1. 3The said sum shall be payable by instalments as shown below.

  2. If at any time any of the said instalments or any part thereof shall be in arrears and unpaid for the period of fourteen days after the time appointed for payment thereof then the whole of the outstanding balance of the said sum shall become immediately payable by us to the Commissioners of HMRC together with interest thereon at the rate applicable from time to time for the purposes of Section 233 Inheritance Tax Act 1984 or any amendment or re-enactment thereof, from the day when default shall be made in payment of such instalment or part thereof. Any such interest shall be paid without deduction of Income Tax.

  3. Notwithstanding the provisions of clause (2) above if the said sum shall not be paid by us by instalments as set out below then the Commissioners of HMRC shall be at liberty either to seek recovery from us under the said Agreement of the said sum or so much thereof as then remains unpaid, or to treat the Agreement as repudiated by us in which case such proceedings may be brought against us as may be necessary to recover the said penalties in respect thereof.


Date……………………….. Signed a) )Personal
  b) )of ……………
  c) )deceased