Inheritance Tax Act 1984 section 222

Appeals against determinations

Section 222 sets out the procedure and time limits for appealing against HMRC determinations of inheritance tax liability, and identifies which courts or tribunals handle different types of appeal.

• A person who receives a notice of determination has 30 days from the date of service to lodge a written appeal with HMRC, setting out the grounds of appeal.
• Appeals are generally notified to the Tax Tribunal, but may in certain circumstances be directed to the High Court (or the Court of Session in Scotland), particularly where the issues are mainly questions of law.
• Any appeal that involves a dispute over the value of UK land must be referred to the appropriate lands tribunal for the part of the UK where the land is situated.
• The appropriate lands tribunal is the Upper Tribunal for land in England or Wales, the Lands Tribunal for Scotland for Scottish land, and the Lands Tribunal for Northern Ireland for Northern Irish land.