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HMRC internal manual

Inheritance Tax Manual

Changes after the issue of the clearance certificate: fraud or failure to disclose material facts

The issue of a clearance certificate does not stop you from collecting tax if there has been a failure to disclose material facts or fraud.

If you receive information that suggests the account was materially incorrect it should be referred to Risk. If they consider it worth pursuit they will refer the case to Compliance to consider whether the new information justifies opening a new enquiry.

Examples of situations where there may have been a failure to disclose material facts include

  • a failure to report a sale of land or buildings (IHTM40144)
  • sales of unquoted shares (IHTM40145) before the certificate was issued
  • where there is evidence to suggest that proper consideration was not given to valuing assets at the date of death.