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HMRC internal manual

Inheritance Tax Manual

Considering a NOD: your objective

In delay cases, your aim is to get the taxpayer to deal with the outstanding matters. Unless there is a valid appeal (IHTM37013) against the Notice of Determination (NOD), then subject to any variation by agreement in writing, it becomes conclusive for Inheritance Tax purposes against the person on whom it was issued. If possible the NOD should specify all matters that can be determined so we can conclude the case, if there is no valid appeal.

In contentious cases, the aim is to resolve the matter concerned by compelling the taxpayer either to accept the official view or to put up counter arguments which can then be tested on appeal to:

  • the Lands Chamber of the Upper Tribunal- where the matter relates to land values
  • the Tax Chamber of the First-tier Tribunal - where it relates to any other matter.