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HMRC internal manual

Inheritance Tax Manual

Procedure in the VOA: determination

The VOA (IHTM23002) will advise us of any case where negotiations reach an impasse and ask whether a determination is necessary – see IHTM23090. In appropriate cases, the VOA will then provide an Appeal Report (IHTM23090). This report will be reviewed by an off-line regional technical advisor in the VOA Chief Executive’s Office before being sent to us. This is to weed out the weaker cases, or those that require more investigation/consideration before they can be properly considered for litigation action. Those that survive this process, and the subsequent consideration by us, move through to the litigation (IHTM23226) stage.