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HMRC internal manual

Inheritance Tax Manual

Considering a NOD: appeals

Under IHTA84/S222(1), any appeal against a determination must be made to the Board in writing within 30 days of the date the Notice of Determination (NOD) was served. In practice the appeal is made to Trusts & Estates.

There is no set form of appeal but the grounds of appeal must be specified. The question of whether enough detail has been given about the grounds of appeal are decided by Litigation. An appeal may be accepted from an agent on behalf of the taxpayer.

If a valid appeal is entered, the relevant matter is still open for negotiation. Litigation will decide whether resuming discussions will be worthwhile or whether we should seek to pursue the matter before the appropriate tribunal. In some circumstances the appeal may be heard by the High Court instead of the tribunal. There is a right of appeal on points of law from any decision of the First-tier Tribunal to the Finance and Tax Chamber of the Upper Tribunal, and from the Lands Tribunal to the Court of Appeal (in Scotland, the Court of Session).