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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals overview: Process for indirect taxes

Conduct of review
Options following review


When we make an appealable indirect tax decision, we will offer a review at the same time. Usually, the decision maker will include the offer of a review in their decision letter, see ARTG3050 and ARTG4230.

The customer may either

  • accept the decision
  • send new information or arguments to the decision maker
  • accept HMRC’s offer of a review, or
  • appeal to the tribunal

The customer may put further arguments or new information to the decision maker. If so, the decision maker may allow a further period of 30 days (which may start from a future date) within which the customer can appeal or accept the review offer.

The decision maker has the responsibility of ensuring that all relevant arguments and information are considered before sending a case for review. The review officer should not be expected to carry out tasks that are properly for the decision maker to complete. However where the taxpayer simply repeats previous arguments or provides irrelevant information, this should not be allowed to delay the review process.

We can allow extensions of time only if we notify the customer to that effect within 30 days of our decision letter (note that the customer does not have 30 days to ask us to do this – they must notify us in sufficient time that we can respond within 30 days). This protects the customer’s review and appeal rights while HMRC’s consideration of the new information or arguments is ongoing.

If the customer wishes to accept the review offer or appeal to the tribunal they should do so within 30 days of the date of the decision letter, or within any extended time limit.

Conduct of review

If the customer accepts the review offer HMRC must carry out the review within 45 days of the date HMRC received the customer’s review acceptance unless another period is agreed (the “review period”), see ARTG4690. Once they have accepted a review offer, the customer may only appeal to the tribunal after either

  • they are sent a conclusion of review letter, see ARTG4820, or
  • the 45 day or other agreed review period has expired.

Options following review

Once the review is completed, the review officer will write to the customer with their conclusions. If the customer does not agree with the review officer’s conclusions they have a further 30 days from the date of the conclusion of review letter within which to appeal to the tribunal.

If the review officer does not write to the customer to tell them the review conclusion within the review period, the review officer must write and tell the customer as soon as possible after it has ended that the decision under review is treated as upheld.

The customer may appeal to the tribunal at any time between the end of the review period and 30 days from the date of the review officer’s letter telling the customer the conclusion that the review is treated as having reached, see ARTG3120.