HMRC review of a decision

Produced by Tolley and written by Anne Redston

The following Personal Tax guidance note Produced by Tolley and written by Anne Redston provides comprehensive and up to date tax information covering:

  • HMRC review of a decision
  • Introduction
  • Coronavirus-related time limit extension
  • The purpose of a review
  • Accepting the offer
  • Refusing the offer
  • Ignoring the offer
  • No offer and no request
  • The review process
  • Appealing to the Tribunal during the review process
  • More...

HMRC review of a decision

Anne is a barrister who sits as a judge of 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.


Before you read this note, you should read the Appealing an HMRC decision ― outline guidance note. It explains that the approach you have to take is slightly different for direct taxes and VAT.

In either case, once HMRC has made an appealable decision, taxpayers normally have 30 days during which they can accept an offer from HMRC to review a decision, or alternatively, request that HMRC review the decision.

Coronavirus-related time limit extension

During the coronavirus (COVID-19) pandemic, it may have been difficult to meet this 30-day time limit (eg if the decision letter was sent to the taxpayer’s or the adviser’s work premises, which were closed, or the taxpayer or the adviser were self-isolating). Even after most of the coronavirus-related restrictions were lifted, difficulties may persist for people who are required to self-isolate if they have symptoms of coronavirus or have tested positive.

For those reasons, HMRC extended the 30-day deadline for

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