I8.111 Administration

I8.111 Administration

The personal representatives of a deceased person and every person who is liable as transferor, including a trustee, must deliver to HMRC an account specifying to the best of their knowledge and belief all relevant property and the value of that property1. However, an account is not required, except in the case of an account to be delivered by personal representatives, if a full and proper account of that property, specifying its value, has already been delivered to HMRC by some other person who is or would be liable for the IHT on the property (unless that other person is or would be liable with the personal representatives jointly as trustee)2. An HMRC officer has the power to obtain information and documents from any person in relation to IHT by means of a notice, provided it is reasonably required to check a person's tax position. For example, in C. Edwards-Moss and D. Edwards-Moss3 it was considered reasonable for HMRC to see the deceased's medical records in order to establish whether the deceased had known that her life expectancy was short so that the transfer of her property for an annuity had been a transfer at an undervalue liable to IHT. HMRC will normally request information informally in the first instance, only issuing a formal notice if the information requested is not provided. Informal requests do not have to be made in writing4.

Where it appears to HMRC that a transfer of value has been made, or where a claim

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