IHTM10802 - Accountability: what is to be included in an account?
The accountable person is required to deliver an account specifying to the best of that person鈥檚 鈥榢nowledge or belief鈥� all 鈥榓ppropriate property鈥� and the value of that property. The account must be one that is prescribed by the Board, IHTA84/S257.
The meaning of knowledge and belief was discussed by Walton J in CIR v Stype Trustees (Jersey) Ltd [1985] STC 394, CTT Cases No 27 (from page 15).
鈥楢ppropriate property鈥� is any property to the value of which the tax is or would be attributable. But this rule is modified (IHTM10812) in the case of transfers on death.