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HMRC internal manual

Inheritance Tax Manual

Investigating accounts: failure to reach an agreement with taxpayers

You should always try to agree the correct tax treatment or value with the taxpayers.  But there will be times when this is not possible either because there is a lack of co-operation by the taxpayers or simply because you are unable to agree how the law applies to particular circumstances or the basis of valuation.

Where there is a lack of co-operation you need to first make sure that you have all the information you need in order to take a view on the appropriate treatment or value for IHT purposes.  If you do not have all the facts you should make full use of delay procedures and where necessary issue information notices (IHTM32191).

In other cases where you are unable to reach an agreement by negotiation (IHTM09071) or perhaps even compromise you should seek to settle the matter by issuing a Notice of Determination (NODs) (IHTM37000).  If an appeal against the notice is received the matter may need to be taken before the First-tier Tribunal, or if land is involved, the Land Tribunal, for a ruling.  But you will only go down this route after full consultation with Litigation.  In most cases you will also have involved Technical before you get to this stage.