Inheritance Tax Act 1984 section 240B

Underpayments involving offshore matters etc.

Section 240B extends the normal time limit for HMRC to recover underpaid inheritance tax to 12 years where the underpayment involves offshore matters or offshore transfers that make the lost tax significantly harder to identify.

• Where underpaid inheritance tax involves property situated or held outside the UK (an "offshore matter"), HMRC has 12 years rather than the normal time limit to bring recovery proceedings.
• The extended 12-year limit also applies where property is transferred overseas after the chargeable transfer but before the relevant account is delivered to HMRC, provided that transfer makes the lost tax significantly harder to identify (an "offshore transfer").
• HMRC loses the right to use the extended time limit if it received relevant information from an overseas authority (under EU law or an international agreement) in time to act within the normal deadline and it was reasonable to expect it to have done so.
• The 12-year extended period does not override any other provision in the Act that allows an even longer recovery period.