IHTM10801 | Accountability: introduction
From HM Revenue & Customs · Inheritance Tax Manual
The rules on accountability are found in .
In general, the accountable person is someone who is liable for any tax () on the assets concerned. But not all those who are liable for tax are accountable and, very exceptionally, a person who is not liable may be required to deliver an account.
The relationship between accountability and liability was discussed by Walton J in CIR v Stype Trustees (Jersey) Ltd [1985] STC 394, CTT Cases No 27.
Different rules may apply in some circumstances to
transfers on death ()
transfers in respect of a qualifying interest in possession in settled property ()
lifetime transfers that are chargeable when made ()
failed potentially exempt transfers (PETs) ()
gifts with reservation (GWRs) ()
relevant property settlements ().