Inheritance Tax Act 1984 section 223B

Appellant requires review by HMRC

Section 223B allows an appellant to require HMRC to carry out a formal review of a disputed inheritance tax matter, and sets out the time limits and circumstances in which this right applies.

  • An appellant can notify HMRC that they require a review of the matter in question, and HMRC must respond with their view within 30 days or a longer reasonable period
  • HMRC must carry out the review in accordance with the procedures set out in section 223E
  • The right to request a review is not available if the appellant has already requested one, if HMRC has already offered a review under section 223C, or if the appeal has already been referred to a court or tribunal
  • The relevant period for HMRC to respond runs from the day they receive the appellant's notification

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