IHTM23225 | Procedure in the VOA: determination
From HM Revenue & Customs · Inheritance Tax Manual
The VOA () will advise us of any case where negotiations reach an impasse and ask whether a determination is necessary – see . In appropriate cases, the VOA will then provide an Appeal Report (). This report will be reviewed by an off-line regional technical advisor in the VOA Chief Executive’s Office before being sent to us. This is to weed out the weaker cases, or those that require more investigation/consideration before they can be properly considered for litigation action. Those that survive this process, and the subsequent consideration by us, move through to the litigation () stage.