IHTM05120 - Grants on credit: introduction and statutory background

»Ê¹ÚÌåÓýapp law requires Personal Representatives (PRs) (IHTM05012) to pay all or part of the Inheritance Tax (IHT) due on the deceased’s estate before they can obtain a grant.

IHTA84/S226 (2) states that all PRs who are liable for the tax by reason of IHTA84/S200 (1)(a) 'shall, on delivery of their account pay all the tax for which they are liable'. »Ê¹ÚÌåÓýapp guidance at IHTM30172 explains how to work out the amount that needs to be paid on delivery. 

»Ê¹ÚÌåÓýapp Senior Court Act 1981/S109 requires that an account (IHTM10011) shows that:

  • the Inheritance Tax (IHT) payable on delivery of the account has been paid, or
  • no such tax is payable,

before a grant can be issued or resealed in the UK.

In certain circumstances (IHTM05123), HMRC will allow a PR to postpone payment of all or part of the tax and interest due on delivery of an account. This is referred to as a grant on credit.

It is important to note that late payment interest will accrue as usual on any unpaid tax.