The catch-22 — why Direct Payment Scheme exists
One of the most frustrating aspects of UK estate administration is the IHT payment deadlock. Understanding why it exists — and why IHT423 resolves it — makes the process less opaque.
The deadlock
To apply for a Grant of Probate (or Letters of Administration), you must confirm that Inheritance Tax has been paid, or that no IHT is due.
But the estate's bank accounts are frozen on death — banks refuse to release funds without sight of the Grant.
This creates a circular dependency: you can't pay IHT without the money, and you can't get the money without paying IHT.
The Direct Payment Scheme resolution
The DPS breaks the deadlock. Participating banks agree to pay HMRC directly from the deceased's account, before the Grant is issued, on receipt of a completed IHT423 form from the executor.
The bank deducts the amount from the deceased's account and sends it to HMRC.
Once HMRC has processed the IHT400 and the payment, it sends the executor a letter containing the unique code and estate values the probate application now requires.
Which institutions participate
Most major UK banks (Barclays, HSBC, Lloyds, NatWest, Santander, Halifax, Bank of Scotland, and others), building societies, and NS&I participate in the DPS.
The full list is available on HMRC's website.
Smaller banks and credit unions may not participate — in that case, you may need to use other estate funds (such as a joint account) to pay HMRC, or arrange a loan.
What if no bank participates or the balance is insufficient?
If the estate has no funds in a participating bank, or the balances are less than the IHT due, you need to find funds from elsewhere: a personal loan by the executors (to be reimbursed from the estate after probate); using joint accounts (which may pass by survivorship and are accessible without probate); life insurance policies that pay out directly to a named beneficiary (also probate-free); or a professional executor who can advance funds from client account.
Discuss options with the solicitor if stuck.
One of the most frustrating aspects of UK estate administration is the IHT payment deadlock. Understanding why it exists — and why IHT423 resolves it — makes the process less opaque.