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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals overview: Rights of appeal

Customers’ rights of appeal are set out in law. In general, there is a right of appeal against tax decisions, assessments, amendments, notices and determinations made by HMRC, see ARTG2160 and ARTG3040.

For example an appeal may be about

  • whether a particular provision or relief applies, or
  • the amount of income or profits HMRC believe to be chargeable to tax, or
  • the amount of tax HMRC believe to be due, or
  • a penalty that is wrongly charged or is too high, or
  • certain types of notice requiring a customer or a third party to provide information to HMRC, or
  • a claim refused by HMRC.

The law entitles a customer who appeals against an appealable decision to have their case considered and decided by a tribunal. This may be at a hearing or on the basis of paper submissions from the parties to the proceedings, see ARTG8370 depending on the type of decision being appealed. See ARTG8350 about categories of tribunal case.

Customers must appeal in writing within the time limit given in the notice of decision, see ARTG2060, usually 30 days.

There is no right of appeal against a Simple Assessment unless the customer has raised a query under s31AA TMA1970 and been given a final response to that query.