The guidance on Requirement to Correct includes an example, No.6, of an omission to report a ten-year charge occasion. However, the legislation [Sch.18 Finance (No.2) Act 2017] only refers to transfers of value. Do forum members agree that amounts subject to charges under Ss.64 and 65 IHTA 1984 are not transfers of value?
See IHTA section 2(3)
(3) Except where the context otherwise requires, references in this Act to chargeable transfers, to their making or to the values transferred by them shall be construed as including references to occasions on which tax is chargeable under Chapter III of Part III of this Act (apart from section 79), to their occurrence or to the amounts on which tax is then chargeable.
I think HMRC would tell you that, since charges under ss 64 and 65 are deemed to be chargeable transfers, they must also be regarded as transfers of value for the provisions you mention.
Irwin Mitchell Private Wealth
The effect of the wording in S.2(3) is to extend the meaning of ‘chargeable transfer’ beyond a transfer of value, to include the occasions mentioned. It does not mean that occasions of charge under Chapter III of Part III are transfers of value…The draftsman might have intended to refer toi chargeable transfers, but he didn’t.