Appealing an HMRC decision
Produced in partnership with Anne Redston

The following Tax practice note produced in partnership with Anne Redston provides comprehensive and up to date legal information covering:

  • Appealing an HMRC decision
  • The starting point
  • Alternative dispute resolution
  • The next step—direct taxes
  • The next step—VAT
  • HMRC review
  • Appealing to the tribunal
  • Status of a decision of the First-tier Tax Tribunal

Appealing an HMRC decision

Coronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and hearings at, the tax tribunals, see Practice Notes: Coronavirus (COVID-19) and tax—impact on tax appeals and tax tribunals and Coronavirus (COVID-19)—tax implications—Tax tribunals.

This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or the judiciary.

This Practice Note outlines the procedure for appealing against a decision made by HMRC. It links to further notes which explain each stage of the procedure.

This Practice Note, and the further Practice Notes on appealing to the tribunal, are only a summary; they do not cover all situations. You may need to take further advice in relation to your client’s appeal position.

Be aware that there are time limits at all stages of the appeal process, and failing to adhere to the time limit may mean that the right to appeal is lost.

This Practice Note does not cover appeals or reviews relating to decisions made by Revenue Scotland in relation to any of the Scottish devolved taxes in respect of which the First-tier Tribunal for Scotland (Tax Chamber) has jurisdiction. For more information, see Practice Note: Appealing a Revenue Scotland decision.

In addition, this Practice Note does not cover judicial review in tax cases. For more information on that,

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