The Inheritance Tax Act 1984 contains provision for the situation where a transfer of value is not notified to HMRC until after a payment has been accepted in full satisfaction of liability for tax on a subsequent transfer. Rather than re-open the later assessment, the Act provides for extra tax to be charged on the transfer reported late.

IHTA 1984, s. 264 applies where the ‘earlier transfer’:

(1)was not notified to the Board in an account under s. 216 (see ¶180-725) or by information furnished under s. 219 before the expiry of the period in which such account must be delivered in terms of s. 216; and

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