A5.711 HMRC review procedure
Request for, or offer of, review
If a taxpayer wishes to dispute a decision, and there is a right of appeal, they should initially appeal to HMRC and where applicable, apply for postponement of tax in the normal way (see A5.704) within the relevant time limit (unless HMRC agrees to a longer period). If HMRC does not agree to an appeal being made outside the relevant time limit, the taxpayer may apply to the tribunal1. Applications to the tribunal for late appeals will be treated as basic cases (see A5.608).
Having made an appeal, the taxpayer then has three options2:
• discuss the matter with the HMRC officer who made the decision, in order to try and settle the appeal by agreement
• request an internal review, or
• notify the appeal to the tribunal
The taxpayer has the statutory right to ask for an internal review of the decision in question, but may choose whether or not to request one. Where a review is requested, the decision under appeal must first be considered by the officer who made it (the 'decision maker'), who then has 30 days (or, where reasonable, a longer period)3 to give the taxpayer their view of the matter. This may be the same as when the appeal was made, or may have changed. After this view is given, the case is sent to a specialist review team4 (see below).
If the taxpayer does not request a review, HMRC may offer one5. Where HMRC offers
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