Appealing an HMRC decision ― outline

Produced by Tolley and written by Anne Redston
Personal Tax
Guidance

Appealing an HMRC decision ― outline

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 appeal position.

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+™
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.   

Powered by Tolley+
  • 07 Aug 2025 13:10

Popular Articles

Associated companies ― from 1 April 2023

Associated companies ― from 1 April 2023Implications of associated companiesFrom 1 April 2023, the rate of corporation tax that a company is subject to depends on the level of its augmented profits. The rate of tax is based on a comparison of the company’s augmented profits against the corporation

22 Mar 2021 10:21 | Produced by Tolley Read more Read more

Winding up a trust ― legal, administrative and compliance issues

Winding up a trust ― legal, administrative and compliance issuesOverviewWhen winding up a trust, there are legal formalities and compliance issues that need to be dealt with, as well as IHT and CGT consequences that flow from the termination. This guidance note considers when and how a trust comes

14 Jul 2020 14:01 | Produced by Tolley Read more Read more

Tax implications of administration and liquidation

Tax implications of administration and liquidationThis guidance considers the tax implications of a company going into administration or liquidation.Introduction to company administration and liquidationCompany going into administrationA company which is in financial difficulty may go into

14 Jul 2020 15:29 | Produced by Tolley Read more Read more