TSEM7376 - Deceased persons: responsibilities of HMRC Trusts Edinburgh - complex cases


HMRC Trusts Edinburgh is responsible for dealing with all aspects of the period of administration where the case is regarded as a complex case (subject to the exceptions at TSEM7366). We would regard a case as complex if:


  • the tax liability for the whole of the administration period is in excess of £10,000, or
  • the estate has a value at the date of death in excess of £2.5m, or
  • the proceeds of assets sold by the personal representatives in any one tax year exceed £250,000
  • the administration of the estate extends beyond the end of the second full tax year from the date of death, or
  • the estate does not fall into any of the above categories but is not straight-forward so cannot easily be dealt with under the informal payments procedures.

Where there is a prolonged administration period the tax consequences can become quite involved and might require technical advice. However the local service office should use discretion in borderline cases. If it considers that the estate’s tax affairs are relatively straightforward and the administration has been completed within two calendar years, any liability can be dealt with informally under the procedures outlined at TSEM7410. This is a general guideline only and further advice on how an estate should be dealt with may be obtained from HMRC Trusts Edinburgh.