Appealing a decision on an application for authorisation

Provides information on how to appeal if you disagree with a decision.

If you disagree with a decision, you can: 

  • accept HMRC’s offer of a review  
  • appeal to an independent tribunal 

You cannot accept HMRC’s offer of a review and appeal to the tribunal at the same time. 

If you accept the offer of a review, an HMRC officer not previously involved in the matter will look at your case again. If you disagree with the outcome of the review, you can still appeal to the tribunal. 

If you want a review, you need to:

  • write within 30 days of the date of the authorisation letter or decision letter, telling HMRC why you think the decision is wrong 
  • send any new information that you want to be considered 

If you need longer than 30 days to send us new information, please contact HMRC to ask for this time limit to be extended. You should ask for any extension before the 30-day deadline.

HMRC will only accept a request for a review outside this period of 30 days where there is a satisfactory explanation for the late submission. You must submit the request for review without undue delay. 

If you do not want a review, you can appeal to HM Courts and Tribunal Service, but you must do this within 30 days of the date of the authorisation or decision letter. 

If you choose to appeal to HM Courts and Tribunal Service, you will need to include a copy of the authorisation letter with your appeal. If you don’t then they may reject your appeal.

You can find more information about your appeal and review rights at: 

• disagree with a tax decision or penalty  

• appeal to the tax tribunal