Inheritance Tax Act 1984 section 223F

Effect of conclusions of review

Section 223F explains the binding effect of HMRC's review conclusions on an inheritance tax dispute, and the circumstances in which those conclusions cease to be final.

• Once HMRC issue notice of their review conclusions, those conclusions are treated as final and binding for inheritance tax purposes.
• The review conclusions settle the matter unless the appellant takes further action by notifying an appeal to the tribunal.
• If the appellant does notify the appeal to the tribunal under section 223G, the review conclusions lose their binding effect to the extent covered by that appeal.
• The section therefore creates a clear decision point: accept the review outcome as final, or escalate the dispute to the tribunal.