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HMRC internal manual

Inheritance Tax Manual

Public Funding for penalty hearings: when you must issue the Public Funding Leaflet

We recognise that a limited number of our penalties are subject to Article 6 (IHTM36402) of the European Convention on Human Rights (EHCR). The Public Funding leaflet must be issued to all taxpayers who elect for a Hearing before the First-tier Tribunal in England and Wales in the following circumstances

  • in all enquiry cases where it appears likely that a IHTA84/S247 or IHTA84/S248 penalty will need to be considered and the leaflet IHT 13 (IHTM36156) is issued, or
  • if the taxpayer or agent requests it (IHTM36414).The leaflet must be issued even if the taxpayer is represented.