An IHT30 clearance certificate is HMRC’s formal confirmation, under section 239 of the Inheritance Tax Act 1984, that all the inheritance tax due on a death or transfer has been paid. Once issued, it discharges the executors and everyone else liable at that title from any further claim for that tax, so they can distribute the estate without the risk of HMRC coming back to them personally. The protection is lost if there was fraud or a failure to disclose material facts, if further assets come to light, or if the estate is later changed by a variation or similar event.

Why do executors need protection at all?

Personal representatives are personally liable for inheritance tax on the free estate under section 200(1)(a) of the Inheritance Tax Act 1984 (IHTA 1984). Section 204(1) limits that liability to the assets they received, or might have received but for their own neglect or default. That still leaves a real risk. An executor who distributes the estate and is then told that a valuation was too low, or that a forgotten account existed, may have to find the extra tax from beneficiaries who have already spent their inheritance.

The exposure can also come from lifetime gifts. Under section 204(8), personal representatives are liable for tax on a failed potentially exempt transfer if the recipient does not pay it within twelve months after the end of the month of death, up to the value of the estate assets. GOV.UK guidance tells executors that HMRC can ask to see estate records up to 20 years after the tax is paid. Our page on accountants as executors and trustees covers the wider duties.

What does a clearance certificate actually do?

Section 239 provides two kinds of certificate:

  • Section 239(1) certifies that the tax on specified property has been or will be paid. It frees that property from HMRC’s charge when it passes to a purchaser.
  • Section 239(2) determines the tax on the whole transfer, or that none is due. Under section 239(3)(b) it discharges all persons from any further claim for that tax and removes any charge on the assets.

HMRC’s Inheritance Tax Manual at IHTM40010 explains that form IHT30 is used both by the taxpayer to apply and by HMRC to certify. For transfers on death, section 239 says HMRC “shall” give the certificate once the conditions are met, so it is not a discretionary favour.

A practical benefit is that values become final. IHTM40141 gives the example of a house agreed with the Valuation Office at £100,000 which the executors later sell for £120,000. If clearance has been issued, HMRC should refuse an offer to pay tax on the higher figure because the value is settled. A claim to reduce a value is still considered on its merits.

Who can apply and who is covered?

Only people liable for the tax can apply, usually the personal representatives for the free estate and the trustees for settled property (IHTM40011). The certificate protects every liable person at the same title for the property specified, even if not all of them signed the form (IHTM40012). It does not protect people at a different title. A certificate issued to the executors does not cover trustees of a trust in which the deceased had an interest, and a separate application is needed at each title even where the same people act in both capacities.

HMRC does not normally certify lifetime chargeable transfers while the donor is alive, because a later death can bring failed gifts into the calculation; once the donor has died, clearance can be given.

When should executors apply?

Section 239(2) allows an application after two years from the transfer, or earlier if HMRC agrees. For a potentially exempt transfer the two years run from the donor’s death (section 239(2A)). HMRC’s own guidance focuses on whether the figures are final: IHTM40013 says the liable persons should apply only when they believe they have reported all assets, liabilities and variations and that the tax position will not need further amendment.

Before issuing the certificate, HMRC checks that the value of the property is finalised, that all tax has been paid or is being paid by instalments, that the value of all aggregable property such as joint assets, trust interests and gifts is finalised, and that there is no outstanding liability on gifts (IHTM40101). An outstanding penalty is not normally a reason to delay. If the application is premature, HMRC may hold it or return it.

Because the certificate at one title can be undermined by late changes at another, HMRC expects trustees to check with the executors, and vice versa, before applying (IHTM40146). The usual sequence is: agree all values, settle any deed of variation, pay the final tax, apply on form IHT30, and only then make final distributions.

What does the certificate not protect against?

Section 239(4) and IHTM40014 set out the exceptions. A certificate does not discharge anyone from further tax where:

  • there has been fraud or failure to disclose material facts. HMRC gives as examples a sale of property or unquoted shares not reported before clearance, or evidence that values were not properly considered (IHTM40143). If a sale contract was signed before the certificate date, the certificate does not stop HMRC reopening the value (IHTM40144);
  • further property is later shown to have been in the estate;
  • too great an increase was claimed on the surviving spouse’s death for an unused nil rate band under section 8A(3) or, since Finance Act 2026, for an unused 100% relief allowance under section 124E(5);
  • tax becomes payable because of a later variation or disclaimer under section 142, a disclaimer of settled property under section 93, or compliance with a testator’s request, a distribution from a will trust or the redemption of a surviving spouse’s life interest on intestacy under sections 143 to 145 (IHTM40147).

HMRC also qualifies certificates to exclude timber left out of account under woodlands relief (IHTM40132) and heritage property that is conditionally exempt (IHTM40133). Tax being paid by instalments does not prevent a certificate on the current form (IHTM40131).

Finance Act 2026 added section 239(4A) for deaths on or after 6 April 2027, when section 150A treats certain pension scheme interests as part of the estate. If such notional pension property is later found after a certificate, the personal representatives are not liable for the tax on it unless the failure to disclose it was due to their carelessness. See pensions and inheritance tax.

Is an IHT30 always needed?

Not always. For an excepted estate, everyone liable is automatically discharged at the end of the prescribed period, which for deaths from 1 January 2022 ends 60 days after the first full grant, unless HMRC has asked for more information or the information given was false or incomplete. HMRC says this has the same effect as formal clearance (IHTM06043).

Where a full account was delivered, HMRC may close its file with a standard closure letter, SL135. IHTM40001 says this non statutory assurance is treated in all respects as if formal clearance had been issued, although executors can still apply on form IHT30 if they prefer. The fact that HMRC has not raised questions within 14 weeks of receiving the IHT400, which GOV.UK says means no further checks will be carried out, is a practical reassurance rather than a statutory discharge.

How might this look for an estate?

Illustration only. Raj and his sister are executors of their mother’s estate, which paid £120,000 of inheritance tax. The Valuation Office has agreed the house value, the shares are valued at the date of death, and a deed of variation redirecting a legacy was signed eight months after death and reported. Once HMRC confirms that the final tax has been received, they send form IHT30. When it comes back certified, they distribute the residue. Two years later an old savings account is found. Tax on that account is still due, because further property is outside the protection, but the certified values of the house and shares cannot be reopened unless something material was withheld.

What mistakes should executors avoid?

  • Distributing the residue before final values are agreed and clearance is received.
  • Applying at one title without checking whether values at another title, such as a trust interest, are settled.
  • Failing to report a sale of the house or shares that took place before the certificate was issued.
  • Making a deed of variation after clearance and assuming the certificate still covers the new position.
  • Treating a certificate as covering deferred woodland or heritage tax, or gifts on which the recipients still owe tax.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.