Inheritance Tax Act 1984 section 221

Notices of determination

Section 221 sets out the process by which HMRC may issue formal written notices of determination to resolve matters relating to inheritance tax transfers of value, including what those notices may cover, how determinations are made, and their binding effect on recipients.

• HMRC may issue a written notice of determination to the transferor, claimant, or any person liable for inheritance tax on a transfer of value, setting out the matters they have determined.
• The notice may cover a wide range of matters including the date and value of the transfer, the identity of the transferor, the tax chargeable, the persons liable, any overpayments and related interest, and any other matter HMRC considers relevant.
• Where facts have been stated in an account or return and HMRC is satisfied that it is correct, the determination must follow that account or return; otherwise HMRC may determine the facts to the best of their judgement.
• A determination is conclusive against the person served unless it is varied by written agreement or overturned on appeal, and if it relates to the value transferred it can also be conclusive against other persons in respect of later transfers of value.