Inherited ISA APS Deadlines

The moment of ticking of what box identifies the completion of 'administration of the estate'?

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As executor of a will, part of which is a considerable Cash ISA balance, I have confirmed from HMRC's website that Additional Permitted Subscriptions (APS) are available to a benefactor up to 3 years from the Date of Death, or 180 days after the completion of administration of the estate by a PR.

Issue of the Grant of Probate was significantly delayed by HMRC, only emerging in January this year after numerous complaints. With DoD being 06/06/2021 this has not left much time under the 3 year rule to recover assets from various financial institutions, which as stated, include a number of Cash ISAs. The 180 day margin may be more helpful, if the exact definition of (or identification of criteria for) the completion of 'estate administration' is established.

Some activities (ie recovery of assets from accounts of the deceased) cannot begin until GoP is issued. Once they are all received, is that the point at which the administration of the estate is defined as complete? Or once they are identified, which may be much earlier? Or some other criteria? Who decides?


To repeat my question:

'The moment of ticking of what box identifies the start of the 180 day period?'

The following thread was helpful, but as far as I understand, did not conclude deifinitively what constitutes the end of estate admin.

Some suggestions were posed:

"The administration period itself commences with the appointment of the PRs and ends when the last asset of the estate has been distributed (assented) to the beneficiaries."

"the admin period automatically comes to an end once the PRs hold the net residue (unencumbered and with certainty) in their hands. This is not the same as when it is "identified" - which may well be some earlier point."

Thanks in advance.




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