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HMRC internal manual

Inheritance Tax Manual

Changes after the issue of the clearance certificate: sales of land or buildings

Whether a failure to report a sale is a failure to disclose a material fact (IHTM40143) will depend primarily on the nature of the asset and any special circumstances relating to the sale. Other factors you should take into account include the interval of time and the extent to which there was a change in either the asset or the market between the death and the sale.

This may be an issue if you think that the Valuation Office, for example, may not have been aware of all of the facts when accepting or agreeing the value, or the land or building may have been sold for a substantially increased value shortly after agreement had been reached.

Where the contract for sale was entered into before the date of the certificate, the certificate should not be regarded as a bar to the value being reopened. You should not reopen the case if there is nothing to suggest that a contract was signed before the date of the certificate even though negotiations for a sale must have been in hand prior to that date.

Before any value is reopened you should check that prior to the sale we did not indicate that the value had been accepted (IHTM30431) in a way that prevents us from reopening it.