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HMRC internal manual

Inheritance Tax Manual

Review of matters determined; conduct of review

If the taxpayer requests a review or accepts HMRC’s offer of a review, the file will be referred to a review officer to conduct the review. For Inheritance Tax the review officer will be a grade 6 or grade 7 who:

  • has not previously been involved in the conduct of the case
  • is not the manager of a person involved in the conduct of the case
  • has not provided advice in connection with the case.

The review is carried out in accordance with the HMRC Appeals, Reviews and Tribunal Guidance that can be found on the HMRC website. External users can find this guidance at

When the review is completed the review officer will issue a letter to the taxpayer setting out the review officer’s conclusions. The review outcome may be to uphold the original decision, to vary it or to cancel it.

The review has to be completed within 45 days or such other period as is agreed between HMRC and the taxpayer. If HMRC does not issue a letter containing the review conclusions by that deadline, HMRC is deemed to have upheld its decision by reason of IHTA84/S223E (8).

Litigation will be responsible for ensuring that reviews are allocated and undertaken within the time limits. Any correspondence received which suggests that a review is requested or accepted should be referred immediately to Litigation, without waiting to obtain the file if it is not to hand.