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.
(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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