IHTM37111 | Review of matters determined: conduct of review

If the taxpayer requests a review or accepts HMRC’s offer of a review, the case will be referred to Solicitor’s Office and Legal Services - Reviews and Litigation to conduct the review.

The review is carried out in accordance with the HMRC Appeals, Reviews and Tribunals Guidance beginning at ARTG4000.

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 The Review Officer 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).

Any correspondence received which suggests that a review is requested or accepted should be dealt with as a matter of urgency given the 45-day statutory time limit