IHTM40143 - Changes after the issue of the clearance certificate: fraud or failure to disclose material facts

The issue of a clearance certificate does not preclude you from collecting tax if there has been a failure to disclose material facts or fraud.

If you receive information that suggests the account was materially incorrect it should be referred to the initial risk assessors. If they consider it worth pursuit they will refer the case to a Compliance Group Team Leader to consider whether the new information justifies re- opening matters.

Examples of situations where there may have been a failure to disclose material facts include

• a failure to report a sale of land or property ( IHTM40144)
• sales of unquoted shares ( IHTM40145) before the certificate was issued, or
• where there is evidence to suggest that proper consideration was not given to valuing the property at the date of death.

If you receive information that suggests the taxpayer may have defrauded HMRC you should refer the case to Compliance Group for the attention of the SCO liaison portfolio holder (IHTM09427).