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HMRC internal manual

Inheritance Tax Manual

Clearance certificates: who can apply for clearance certificates?

Only those who are liable (IHTM30011) for Inheritance Tax can apply for a clearance certificate.

The liable persons are usually

  • the personal representatives (IHTM05012) for property passing under the deceased’s will or intestacy, or
  • the trustees (IHTM16050) for property in a settlement (IHTM16042).

You may receive a request for clearance in respect of a lifetime transfer that was chargeable when made (IHTM04067). You should normally tell the applicants that we do not give clearance in these circumstances. It is considered that the normal process of assessment and payment of tax are sufficient evidence that the liability has been satisfied.

We do not issue clearance as the subsequent death of the transferor may bring failed potentially exempt transfers (IHTM14511) into cumulation. Clearance can be given if the transferor has subsequently died and you are satisfied that no further liabilities can arise in respect of the transfer.