HMRC review of a decision

By Tolley and written by Anne Redston
HMRC review of a decision

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

  • HMRC review of a decision
  • Introduction
  • 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
  • Appeal to the Tribunal

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.

This guidance note, and the other related guidance notes on Tribunal appeals, sets out the position before the coronavirus (COVID-19) pandemic. However, Tribunal appeals, hearings and related procedures have all been affected by the coronavirus pandemic. You are strongly advised to read Impact on the Tax Tribunals  within the Tolley COVID-19  toolkit, as that commentary summarises the current position.


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

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

TMA 1970, ss 49B, 49C; VATA 1994, ss 83A83C
The purpose of a review

HMRC says that in carrying out a review, it has two main aims:

  • to help to resolve the dispute, by considering whether there is scope for negotiations and compromise
  • to take a fresh look at the decision in an ‘objective and balanced way’. The review should identify decisions that are wrong or unsound, and decisions that they would not want to take before a Tribunal


In considering whether or not HMRC would want to take the case to the Tribunal, the review

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