If the tax claim concerns a deceased person or their estate, the applicant State should inform the requested State about the limit of the recoverable amount and provide details of the value of the estate or, where the claim is against the beneficiaries of the estate, the property acquired by each beneficiary of the estate as Article 11 paragraph 3 of the Convention stipulates that the amount of tax recovered from each of the persons benefiting from the estate against whom a claim can be made shall not exceed the value of their portion of the estate.
