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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
, see all updates

Communications: Handling of complaints/compliments: judicial review

This is the remedy which the Courts use to control the way in which we exercise powers and carry out duties.

Any case

  • where judicial review is mentioned, or
  • where there is some indication that the parties are considering a challenge by legal proceedings other than via the NOD procedures (IHTM37001), or
  • where the taxpayer or agent argues, for example, that we should not deny a relief or make an assessment following on from an earlier official statement/alleged practice

should be referred immediately to the Assistant Director in Litigation Group.