½Û×ÓÊÓƵ

Where the Board is satisfied that IHT has been or will be paid on a chargeable transfer (including relevant property exit and periodic charges¹) of specified property, it must, on application at any time of the person liable, give a certificate to that effect if the transfer occurred on death or if the lifetime transferor has died. In other cases, the Board may issue a certificate but it is under no obligation to do so².

A certificate discharges the property specified in it from the Inland Revenue charge on its acquisition by a purchaser³ (see I11.440 onwards). It does not discharge the persons liable.

However, in the case of a discretionary trust where the trustees have obtained a certificate of discharge in respect of a distribution out of the trust and additional tax is subsequently charged in respect of the distribution by reason of the settlor's fraud, default or neglect (see I11.410), HMRC has historically said⁴ that it will