Appealing an HMRC decision
Produced in partnership with Anne Redston of Temple Tax Chambers
Appealing an HMRC decision

The following Tax guidance note Produced in partnership with Anne Redston of Temple Tax Chambers 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

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 judicial review in tax cases. For more information on that, see Practice Notes:

  1. Judicial review in tax cases at the High Court, and

  2. Tax and judicial review in the tax tribunals

For a flowchart showing how a case normally proceeds from an appealable HMRC decision, to the First-tier Tax Tribunal (FTT), the Upper Tribunal (UT), the Court of Appeal and finally to the UK Supreme Court, see: Legal system for civil tax appeals in England and Wales—flowchart. As can be seen on the Flowchart, it is also possible for some UT decisions to leapfrog the Court of Appeal