Preparing for the appeal to the Tribunal

By Tolley and written by Anne Redston

The following Corporation Tax guidance note by Tolley and written by Anne Redston provides comprehensive and up to date tax information covering:

  • Preparing for the appeal to the Tribunal
  • Introduction
  • The appeal form
  • Classification of the case
  • Directions
  • Witnesses
  • Bundles
  • Skeleton arguments


This guidance note outlines what you should do after your client has decided to appeal to theTribunal, and takes you up to theday of thehearing. For thenext stage, see theWhat happens at thehearing guidance note.

Before you read this guidance note you should read theAppealing an HMRC decision: outline guidance note. Remember that this guidance note and theother guidance notes on appealing to theTribunal 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. If your client’s appeal is to theScottish First-tier Tribunal, theprocedure may not be thesame as that set out here. You are advised to take specialist advice.

The appeal form

You must submit theappeal form to theTribunals Service within thetime limit. For a discussion of time limits, see theAppealing an HMRC decision: outline guidance note.

It is possible that fees will be charged for Tax Tribunal hearings. See theShould I appeal to theTribunal? guidance note.

The application to appeal can be made online via theGOV.UK website . You must include a scan or photo of theoriginal notice or review conclusion letter with theapplication and (if you are not a legal representative) authorisation from your client to act on his behalf. There is a save option which allows you to return to theapplication later if you require further information to complete theform.

The online appeal form includes step-by-step guidance on completing an appeal, and gives a reference number when an appeal has been submitted successfully. Even if you have completed many appeal forms, it is a good idea to read through theguidance each time, in case there is something which is relevant to this

More on Appeals and case tracker: