The following Corporation Tax guidance note by Tolley and written by Anne Redston provides comprehensive and up to date tax information covering:
This guidance note is only a summary and does not cover all situations. You may need to take further advice in relation to your client’s appeal position. If your client’s appeal is against a decision by Revenue Scotland, the procedure may not be the same as that set out here. You are advised to take specialist advice.
Before you read this note you should read the Appealing an HMRC decision: outline guidance note. That note explains that the approach you have to take is slightly different for direct taxes and indirect taxes.
In either case, once HMRC has made an appealable decision, the taxpayer normally has 30 days during which he can accept an offer from HMRC to review a decision, or alternatively, request that HMRC reviews the decision.
HMRC says that in carrying out a review they have two main aims:
In considering whether or not HMRC would want to take the case to the Tribunal, the review officer should ‘only pursue sensible cases with good prospects of success’. In particular, he should have regard to the Litigation and Settlement Strategy, and specifically:
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