Section 221 Content of notice given pending an appeal

This section applies where an accelerated payment notice is given by virtue of section 219(2)(b) (notice given pending an appeal).

The notice must—

if the denied advantage consists of or includes an asserted surrenderable amount (within the meaning of section 220(4A)), specify that amount and any action which is required to be taken in respect of it under section 225A.

“The disputed tax” means so much of the amount of the charge to tax arising in consequence of—

as a designated HMRC officer determines, to the best of the officer's information and belief, as the amount required to ensure the counteraction of what that officer so determines as the denied advantage F4(and disregarding any dispute which has been referred to a tribunal under section 12ABZB(3) of TMA 1970 but not yet determined).

“The denied advantage” has the same meaning as in section 220(5).

If a notice is given by reason of two or all of the requirements in section 219(4) being met, the denied advantage is to be determined as if the notice were given by virtue of such one of them as is stated in the notice as being used for this purpose.

In this section a reference to an assessment to tax, in relation to inheritance tax, is to a determination.