Appealing an HMRC decision ― outline

Copyright © 2026 LexisNexis
Produced by Tolley and written by Anne Redston
Personal Tax
Guidance

Appealing an HMRC decision ― outline

Copyright © 2026 LexisNexis
Produced by Tolley and written by Anne Redston
Personal Tax
Guidance
imgtext

Anne is a barrister who sits as a judge of the Upper Tribunal (Tax and Chancery Chamber) and the First-tier Tax Tribunal. The commentary in this guidance note is her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary.

Introduction

This note outlines the procedure for appealing against a decision made by HMRC. It links to further notes which explain each stage of the procedure. See also the Flowchart ― appeal process at a glance ― direct taxes and Flowchart ― appeal process at a glance ― VAT which visually summarise the process.

Note that the Government has proposed an alignment of the processes for appealing direct taxes and VAT decisions. For more details, see the Tax Administration Framework Review: Improving HMRC’s approach to dispute resolution (Apr 2025).

This guidance note and the further 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 the taxpayer’s

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
TAKE A FREE TRIAL NOW
Anne Redston
Anne Redston

Barrister

Anne Redston is a barrister and consultant editor of Tolley's Yellow Tax Handbook. She is also a judge of the Upper Tribunal (Tax and Chancery Chamber), the First-tier Tax Tribunal and the Social Entitlement Tribunal. She is a Chartered Accountant and Chartered Tax Adviser, and a Fellow of both Institutes.   

Read moreRead more
Powered by Tolley+™
  • 07 Aug 2025 13:10

Home/ Tolley Tax Guidance/ Personal Tax / Enquiries, penalties and appeals

Popular Articles

Personal Tax

Married couple’s allowance

Married couple’s allowanceThe married couple’s allowance (MCA) is only available if one of the two spouses or civil partners was born before 6 April 1935. This means that one member of the couple must be at least 89 years old on 5 April 2024 to qualify for an allowance in the 2023/24 tax year.There

14 Jul 2020 12:13 | Produced by Tolley Read more Read more
Employment Tax

Parking provision and expenses

Parking provision and expensesCar parking facilities at or near to the employee’s workplaceThere is an exemption from tax and NIC where an employer provides parking, or pays for or reimburses an employee for the costs associated with car parking at or near the place of work; there are no reporting

14 Jul 2020 11:09 | Produced by Tolley Read more Read more
Trusts and Inheritance Tax

Bare trusts ― income tax and CGT

Bare trusts ― income tax and CGTThis guidance note explains how trustees of bare trusts are treated for income tax and capital gains purposes. Although a bare trust is, in equity, a type of trust, for both income tax and capital gains tax purposes its existence is transparent. This means that no tax

14 Jul 2020 15:34 | Produced by Tolley Read more Read more