Disputes with HMRC: appeals

FORTHCOMING CHANGE: A consultation (closing on 7 July 2025) seeks views on options for simplifying, modernising and reforming HMRC’s approach to dispute resolution with the aim of raising awareness of the dispute resolution processes and improving access to (and take-up of) alternative dispute resolution (ADR) and statutory review processes. The consultation also proposes aligning and simplifying the approach for appeals processes to combine the benefits of the different approaches currently used for direct and indirect tax disputes. For more information, see News Analysis articles: Tax update spring 2025—Tax analysis—Taxes management and dispute resolution and Tax update spring 2025—Improving HMRC’s approach to dispute resolution.

Most HMRC decisions are able to be appealed by the taxpayer.

Once a taxpayer has received an appealable decision, the clock has already started to run for:

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requesting an HMRC review of that decision, and
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appealing it to the First-tier Tax Tribunal (FTT)

Below is an overview of the appeals procedure and the matters to be considered by a taxpayer:

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before launching an appeal, and
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throughout the appeal process

The procedure differs if the

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