IHTM38022 - Payment problems: tax not in dispute


Tax not in dispute is the minimum amount of tax and/or interest known to be due on the current facts of the case. A calculation for tax not in dispute should omit any increases to a chargeable estate that have not been agreed with the taxpayer. It should include any claimed reductions in the value of the estate that are still the subject of an enquiry.

Example 1

Property returned in IHT400 at£200,000
DV estimates value at£250,000

The increase is disputed by the personal representatives and therefore a calculation should be raised based on the returned value of £200,000, until the dispute is settled.

The net result will be a provisional calculation for the minimum amount of tax and/or interest payable that can be defended before the First-tier Tribunal.