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

Employment Tax

Loans provided to employees

Loans provided to employeesEmployers sometimes provide their employees with loans, sometimes charging interest and often not, either as part of the reward package or to help the individual meet significant expenditure. For example, it is common to provide loans for the purchase of annual travel

14 Jul 2020 12:11 | Produced by Tolley Read more Read more
Personal Tax

Payment of tax due under self assessment

Payment of tax due under self assessmentNormal due dateIndividuals are usually required to pay any outstanding income tax, Class 2 and Class 4 national insurance, and capital gains tax due for the tax year by 31 January following the end of the tax year (ie 31 January 2025 for the 2023/24 tax year).

14 Jul 2020 12:52 | Produced by Tolley Read more Read more
Employment Tax

Income tax paid on behalf of employee

Income tax paid on behalf of employeeIntroductionEmployers may wish to make payments of employment income to an employee / director without the employee suffering a tax or NIC cost on that pay. In other words, the employer wants to pay an amount net of tax and NIC. In some instances, often with

14 Jul 2020 11:58 | Produced by Tolley in association with Paul Tew Read more Read more