The First-tier Tribunal is the first instance tribunal for most jurisdictions and so the majority of appeals will commence in this tier. For tax purposes, the First-tier Tribunal typically replaces the General and Special Commissioners, as well as the s 706/704 and VAT and Duties Tribunals.
Both the First-tier and Upper Tribunals are divided into 'chambers', which focus on different subject areas, thus ensuring that the panels hearing the appeals have the appropriate level of expertise. There are seven First-tier chambers, one of which is devoted to tax matters. The Upper Tribunal is organised into four chambers, one of which is 'Tax and Chancery'. Each chamber has its own president reporting to the overall head of the tribunals, the Senior President (see A3.704).
Note that tax credit appeals were transferred to the Social Entitlement Chamber of the First-tier Tribunal in November 2008, although it is understood that it is government policy that tax credits will join the Tax Chamber at a later stage. As these are not dealt with in the Tax Chamber, they are currently unaffected by the internal review procedure (see A5.710–A5.711). Once these cases do transfer, they will be subject to the review procedure in the same way as other tax appeals.
The First-tier Tribunal (Tax Chamber) considers both straightforward and more complex cases on