HMRC review of a decision

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

HMRC review of a decision

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.

This guidance note is only a summary and does not cover all situations. You may need to take further advice in relation to any particular appeal position. If the 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.

Introduction

Before you read this note, you should read the Appealing an HMRC decision ― outline guidance note.

The approach you have to take is slightly different for direct taxes and VAT, as explained below. 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

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+™
  • 13 Aug 2025 08:10

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

Popular Articles

Personal Tax

Timing of disposal for capital gains tax

Timing of disposal for capital gains taxDate of disposalThe date of the disposal determines the period in which the gain is subject to capital gains tax (CGT). When the rates of CGT change, the determination of the date of disposal can also affect the rate of CGT that applies to the gain.See the

14 Jul 2020 13:50 | Produced by Tolley Read more Read more
tag-icon Year-end tax planning
Corporation Tax

Double tax relief

Double tax reliefWhen income arises in a foreign country to a UK resident company and that income is taxable in that foreign country, the UK may give the company relief for the foreign tax by crediting the foreign tax against the UK tax charged on that income. This might include withholding tax on

14 Jul 2020 11:31 | Produced by Tolley Read more Read more
Corporation Tax

Entity classification

Entity classificationImplications of entity classificationIf a subsidiary is established, it is important to determine how it will be treated for UK tax purposes as this will determine the basis on which it is taxed. A subsidiary may either be transparent (like a partnership, where the individual

14 Jul 2020 11:37 | Produced by Tolley Read more Read more