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HMRC internal manual

Inheritance Tax Manual

Qualifying the certificate: conditionally exempt property

You should specifically exclude heritage property (IHTM04111) on which tax has not been paid. You should qualify the certificate by writing:

‘This certificate does not operate as a discharge from any tax which may become payable on the happening of a chargeable event in respect of property conditionally exempted under IHTA84/S30’.

If the property concerned was granted conditional exemption under IHTA84/S31 or FA75/S34 or FA76/S76 you should amend the statutory reference accordingly.

In the case of articles forming part of a set to which FA75/S33 (4) applies you should extend the exclusion to cover all such articles so long as tax remains unpaid in respect of any of them.