Section 223C — Inheritance Tax Act 1984: HMRC offer review

HMRC offer review 223C 1 Subsections (2) to (6) apply if HMRC notify the appellant of an offer to review the matter in question.

2 When HMRC notify the appellant of the offer, HMRC must also notify the appellant of HMRC's view of the matter in question.

3 If, within the acceptance period, the appellant notifies HMRC of acceptance of the offer, HMRC must review the matter in question in accordance with section 223E.

4 If the appellant does not give HMRC such a notification within the acceptance period, HMRC's view of the matter in question shall be conclusive for the purposes of this Act.

5 The same consequences shall follow for all purposes as would have followed if, on the date that HMRC gave notice of their view, the tribunal had determined the appeal in accordance with its terms.

6 Subsection (4) does not apply to the matter in question if, or to the extent that, the appellant notifies the appeal to the tribunal under section 223H.

7 HMRC may not notify the appellant of an offer to review the matter in question (and, accordingly, HMRC shall not be required to conduct a review) if—

a HMRC have already given a notification under this section in relation to the matter in question, b the appellant has given a notification under section 223B in relation to the matter in question, or c the appellant has notified the appeal to the court under section 222(3), the appropriate Lands tribunal under section 222(4) or the tribunal under section 223D.

8 In this section “ acceptance period ” means the period of 30 days beginning with the date of the document by which HMRC notify the appellant of the offer to review the matter in question.