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HMRC internal manual

Inheritance Tax Manual

Procedure in the VOA: negotiation

Where agreement is not reached at the inspection and valuation (IHTM23223) stage, further negotiations take place. At this point, the VOA (IHTM23002) will notify us of the respective values on the table by issuing an interim report on VO 1103, either when a case moves to the negotiation stage, or at 60 days, whichever occurs earliest. (This will be an opportunity for you to ‘risk assess’ the case and to take appropriate action.)

Depending on the complexity of the case and the valuation difference at stake, negotiations may continue for some while. All cases reaching 120 days without resolution are subject to a joint review, triggered by the VOA. This should agree a case plan and timetable for future action.