If you disagree with HMRC's decision about your tax adviser registration
Find out about statutory reviews, tax tribunal appeals and applying for temporary relief, if you disagree with HMRC’s decision about your tax adviser registration.
If you disagree with a decision about your tax adviser registration, you may be able to:
- accept HMRC’s offer of a statutory review
- appeal to the tax tribunal
We will tell you if you can do this when we share the decision about your application with you.
Statutory review
You may be able to get the decision made about your tax adviser registration reviewed by someone in a different team who was not involved in the original decision. This is known as a ‘statutory review’.
You will have 30 days from the date we notify you to accept the offer of a review. You cannot accept a statutory review if you have already appealed to the tax tribunal.
If you miss the deadline, HMRC may allow a late request if you have a reasonable excuse. You must contact HMRC when your reasonable excuse has ended and explain why you’re late in accepting the offer of a review. If we reject your late request, you can ask the tax tribunal to accept a late appeal.
The review usually takes up to 45 days, but we will contact you if it is likely to take longer.
After the review, we will write to you to tell you if the original decision:
- remains unchanged
- has changed
- has been cancelled — if this happens you do not need to do anything
If you disagree with the review outcome, you can appeal to the tax tribunal.
How to accept a statutory review offer
To accept HMRC’s offer of a statutory review, you must contact HMRC Legal Group.
You must tell HMRC:
- your name or business name
- the reference number for your registration application
- the reasons why you disagree with the decision, and any supporting evidence you want HMRC to consider
You can email HMRC at: reviews@hmrc.gov.uk.
You can also write to HMRC at:
HMRC Legal Group
HM Revenue and Customs
BX9 1ZT
Appeal to the tax tribunal
You can appeal to the tax tribunal either instead of accepting HMRC’s offer of a statutory review, or after you have received the outcome of a statutory review.
You can find out how to appeal to the tax tribunal. You will need to include a copy of the decision you are appealing against.
Temporary relief
You may apply for temporary relief if you do not think your business will be able to continue to trade while a statutory review or tax tribunal appeal is ongoing.
Temporary relief allows you to continue interacting with HMRC on behalf of clients whilst your review or appeal is ongoing.
You will be able to apply for temporary relief if you are challenging:
-
the rejection of your application to register as a tax adviser
-
a decision to suspend your tax adviser registration
When you apply, you will be asked to provide evidence to support your request, which may include sharing details about your review or appeal. HMRC may also consider whether you acted quickly in accepting a review or making an appeal.
If the rejection or suspension is only because of outstanding tax returns or unpaid tax (by your business or a relevant individual), you will automatically get temporary relief if you apply for it.
If HMRC refuses temporary relief, or grants it subject to conditions, you may be able to appeal that decision.
How to apply for temporary relief
We’ll update this guidance with information about how to apply when it is available.