PART 2TRANSITIONAL PROVISION
Inheritance tax: underpayments6
In a case under section 240(2) IHTA 19847, where —
a
the chargeable transfer took place on or before 31st March 2011, and
b
a loss of tax was brought about deliberately by any person (or a person acting on behalf of such a person),
the period within which proceedings may be brought is the period of 6 years beginning when the deliberate conduct comes to the knowledge of Her Majesty’s Revenue and Customs or the period of 20 years provided in section 240(5) IHTA 19848, whichever ends soonest.