If the Board are satisfied that too much IHT or interest thereon has been paid on a chargeable transfer, the Board must repay the excess unless the payment was based on a previous view of the law then generally received or adopted in practice1 (see I11.412) or the repayment claim was made more than four years after the date of the payment, or last instalment payment, of IHT and interest thereon2.
In HMRC's view the four-year time limit does not apply where the charge to IHT itself (as distinct from the amount of tax charged) was based on an error of fact (for example the assumption that a person in fact alive has died), and for this purpose
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