What right does section 219B of the Inheritance Tax Act 1984 provide?

Section 219B provides a right of appeal against HMRC notices issued under section 219A requiring the production of documents, accounts or particulars relevant to inheritance tax. The appeal must be lodged within thirty days of the notice date. If the tribunal confirms the requirement, the person must comply within thirty days of the determination.

What is the time limit for appealing a section 219A notice under section 219B?

The appeal must be brought within thirty days of the date on which the section 219A notice was issued. This is a strict deadline under United Kingdom inheritance tax law, so prompt action is essential if there are legitimate grounds to challenge the scope or reasonableness of the HMRC notice requiring document production.

Is there a further right of appeal if the tribunal confirms the section 219A notice?

No. If the tribunal hears the appeal and confirms the requirement under section 219A, the person must comply within thirty days of the tribunal's determination. The tribunal's decision is final and there is no further right of appeal beyond that stage, making the initial appeal the sole opportunity to challenge the notice.

Does section 219B still apply after its repeal on 1 April 2010?

Section 219B was repealed from 1 April 2010 by the Finance Act 2009 Order. However, it continues to apply to any section 219A notice issued before that date. Penalty provisions under section 245A also remain in force for such pre-repeal notices, meaning the appeal mechanism is relevant only to historic cases.

Inheritance Tax Act 1984 section 219B

Appeal against requirement to produce documents etc.

Section 219B provides a right of appeal against HMRC notices requiring the production of documents, accounts or particulars in connection with inheritance tax.

A person who receives a notice under section 219A requiring them to produce documents, furnish accounts or provide particulars may appeal against that requirement.
The appeal must be brought within thirty days of the date of the section 219A notice.
If the tribunal confirms the requirement, the person must comply within thirty days of the appeal determination, and there is no further right of appeal against that determination.
This section was repealed with effect from 1 April 2010, but continues to apply to any notice given before that date.

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