1 April 2009 saw the extensive reformation of the tax appeals system.
Prior to this date the hearing of tax appeals and administrative processes differed between the various tax tribunals (the General Commissioners, the Special Commissioners, the VAT and Duties Tribunals and the Section 706/704 Tribunals). Reform of these tribunals had been under consideration for a number of years, but further impetus was given to this when HMRC were established in 2005 and the existing systems were transferred from the former departments, with the result that different rules and procedures applied across different taxes administered by a single department.
The Tribunals, Courts and Enforcement Act 2007 (TCEA 2007), which received Royal Assent on 19 July 2007, provided the legal framework for a new, unified, two-tier tribunal system, the First-tier Tribunal and the Upper Tribunal (see A5.605 and A5.611 below). Within this two-tier system specialist tax chambers have been introduced, the Tax Chamber of the First-tier Tribunal and the Tax and Chancery Chamber of the Upper Tribunal. These specialist chambers provide a single coherent and consistent tax appeals system capable of hearing the full range of direct