IHTM37011 - Considering a Notice of Determination: when is it appropriate?

Most commonly, consideration of a Notice of Determination (NOD) will arise in the following circumstances

· when the taxpayer persistently refuses to pay a calculation of tax, and/or

· to bring an Inheritance Tax dispute to a head.

Before considering a NOD, it is essential to gather enough information and evidence from the taxpayer and/or other sources to be able to decide on the correct position. If the taxpayer does not supply that information, you should consider using information notices (IHTM32191) to get these details in the first instance.

The NOD procedures are a standard tool, rather than an ultimate deterrent.