Obtaining IHT clearance where bulk of the estate goes to charity

I would be interested in the views of others on the following situation. The deceased left an estate of approximately £3 million. She gave some free of tax legacies to non-exempt beneficiaries which exceeded her nil rate band and gave the residue to well known charities. The value of the legacies was grossed up for IHT and the tax paid. I have asked HMRC whether they would be willing to issue a clearance certificate without me having to submit a statement of amendments to the values of the sizeable number of assets which included a large portfolio of shares. However the response I received was that they would like me to do this for sake of completeness. As this exercise would involve quite a bit of time and obviously would cost the charity beneficiaries, I am not inclined to undertake that exercise when at the end of the day there could be no further tax to pay. Am I being unreasonable? Can HMRC insist that I do so?

Patrick Moroney
BWL solicitors

It has just occurred to me that my posting did not give the full facts. My excuse is that it was in the early days of lockdown No. 1 when I was unable to go to my office and had not set up a work from home arrangement. The IHT 400 had been submitted and payment of the tax on the grossed up legacies had been made. However HMRC issued an assessment asking for a further, I think, £1300 (I am now working from home so I don’t have the paper file to check). As there was an urgency in getting probate, (there was a large valued portfolio of shares which needed to be sold) my colleague, who was looking after matters, paid this on the basis that it would be investigated by me when I returned. Nevertheless there was a delay in the IHT 421 being sent by HMRC direct to HMCTS and then a further delay at that office before probate was issued, about three months from application, if my memory serves me right. On my return, I looked into the matter of the IHT calculation and indeed found that HMRC had made a mistake and that my calculation was correct. I had after all used their own online calculator. I therefore wrote to them and they admitted their error and apologised and said that a refund would be made once I had notified them of any amendments to the value of the estate. As the only tax liability was in respect of the grossed up legacies, I pointed out that there could be no further tax to pay and that I did not see the need to provide them with a statement of amendments, to use their phrase, “for sake of completeness”. That correspondence took place I think in October and I sent a further letter in December but to date no response. I can’t therefore wind up the estate until I get the refund. I am not too bothered about getting an IHT clearance even though 2 of the partners and I are executors. So my question is, are HMRC right in withholding the refund until I provide them with a schedule of amendments? I think not.
As a result of the delay in probate being issued, the shares could not be sold till September and the estate lost some £100k plus compared to the probate value.
Sorry for the length of this.

Patrick Moroney