Commentary

A5.711 HMRC review procedure

Administration and compliance

A5.711 HMRC review procedure

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:

  1.  

    •     discuss the matter with the HMRC officer who made the decision, in order to try and settle the appeal by agreement

  2.  

    •     request an internal review, or

  3.  

    •     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

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