IHTM32205 - IHTA84/S219A notices: authority to issue a notice

The officer working the enquiry who, in practice, may be in Band O upwards can issue the notice. However, before issuing a formal notice under IHTA84/S219A, you should obtain the approval of a Grade 7, which should be recorded in writing. If you are in PC&S you should refer all cases in which you think a formal notice is appropriate to PCTS (Compliance Group in Edinburgh) who will consult with Litigation in appropriate circumstances. If you need to ask for information that the parties have argued is ‘privileged’ or documents that contain tax advice then the papers must be referred to Litigation before a notice is issued.