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Basic rules for underpaid IHT

Where too little IHT has been paid and no certificate of discharge has been obtained¹ (see I11.413), the underpaid IHT is payable with interest from the time when the full amount of IHT should have been paid² whether or not the amount so far paid was that specified in a notice of determination³. The reason for the underpayment is immaterial unless based on a previous view of the law then generally held by the Board in which case the Board is bound by that view⁴.

However, once the Board has accepted payment of IHT in full satisfaction of an account, no proceedings can be brought for underpaid IHT after the expiration of the four-year period beginning with the later of⁵:

1. Ìý

   (a)ÌýÌýÌýÌý the date on which the payment or the last instalment payment was made and accepted, and

2. Ìý

   (b)ÌýÌýÌýÌý the date on which it became due

However, the time limits for offshore matter may be longer – see below.

Thereafter, any