Inheritance Tax Act 1984 section 223E

Nature of review etc.

Section 223E sets out how HMRC must conduct a review of a disputed inheritance tax matter, including the scope of the review, the time limits for notifying the appellant of the outcome, and what happens if HMRC fail to meet those time limits.

• HMRC determine the appropriate nature and extent of the review, taking into account steps already taken to decide the matter and any efforts to resolve the disagreement
• The review must consider any representations made by the appellant, provided they are submitted in time for HMRC to consider them properly
• The review may conclude that HMRC's original view is upheld, varied, or cancelled, and HMRC must notify the appellant of the conclusion and reasoning within 45 days of the relevant day (or an agreed alternative period)
• If HMRC fail to notify the appellant within the required time, the review is automatically treated as upholding HMRC's original view, and HMRC must still notify the appellant of that deemed conclusion