Inheritance Tax Act 1984 section 223

Late notice of appeal

Section 223 deals with the circumstances in which a late notice of appeal against an HMRC determination may still be accepted after the normal deadline has passed.

• Where the normal deadline for appealing an HMRC determination has been missed, it is still possible to submit a late notice of appeal with either HMRC's agreement or tribunal permission.
• HMRC must agree to accept a late appeal if the appellant makes a written request, had a reasonable excuse for missing the deadline, and submitted the request without unreasonable delay once the excuse no longer applied.
• If HMRC do not agree to accept the late appeal, the appellant can ask the tribunal for permission to proceed.
• HMRC are required to notify the appellant of their decision on whether they agree to the late notice of appeal.