Commentary

I11.312B Conduct of the review

IHT, trusts and estates

I11.312B Conduct of the review

I11.312B Conduct of the review

The review procedure is internal to HMRC and although described as independent, there may be some doubt as to whether it is truly independent. However, the reviewing officer is not a person who has been previously involved in the case nor a person connected with the initial decision maker, ie by line management.

Where a review is requested or offered and accepted, HMRC must carry out the review and notify the appellant of the conclusions of the review within the period of 45 days beginning with:

  1.  

    •     (where the appellant requested the review) the day HMRC notified him of its view of the matter in question, or

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