81 Offshore matters or transfers: inheritance tax

81  Offshore matters or transfers: inheritance tax

(1)     IHTA 1984 is amended as follows.

(2)     In section 240 (underpayments), in subsection (3), at the end insert “and to section 240B (underpayments involving offshore matter etc).”

(3)     After section 240A insert—

“240B Underpayments involving offshore matters etc

(1)     This section applies in a case within section 240(2) which involves a loss of tax in relation to a chargeable transfer, where—

(a)     the lost tax involves an offshore matter, or

(b)     the lost tax involves an offshore transfer which makes the lost tax significantly harder to identify.

(2)     Proceedings for the recovery of the lost tax may be brought at any time not more than 12 years after the later of the dates in section

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