Inheritance Tax Act 1984 section 223C

HMRC offer review

Section 223C sets out the process that applies when HMRC offer to review a matter under dispute, including the requirement for HMRC to share their view, the 30-day deadline for acceptance, and the consequences of not responding.

• When HMRC offer a review, they must at the same time tell the appellant what HMRC's view of the matter is.
• The appellant has 30 days from the date of HMRC's offer letter to accept; if the offer is accepted, HMRC must carry out the review.
• If the appellant does not accept within 30 days, HMRC's view becomes final and is treated as though the tribunal had decided the appeal on those terms — unless the appellant refers the appeal to the tribunal instead.
• HMRC cannot offer a review if they have already done so on the same matter, or if the appellant has already requested a review or referred the appeal to the court or tribunal.