IHTM36412 | Public Funding for penalty hearings: when you must issue the Public Funding Leaflet
From HM Revenue & Customs · Inheritance Tax Manual
We recognise that a limited number of our penalties are subject to Article 6 () of the European Convention on Human Rights (EHCR). The Public Funding leaflet must be issued to all taxpayers who elect for a Hearing before the First-tier Tribunal in England and Wales in the following circumstances
in all enquiry cases where it appears likely that a or penalty will need to be considered and the leaflet IHT 13 () is issued, or
if the taxpayer or agent requests it ().
The leaflet must be issued even if the taxpayer is represented.