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HMRC internal manual

Appeals reviews and tribunals guidance

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HM Revenue & Customs
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Reviews and appeals overview: Introduction appeal to the tribunal

In most cases where a customer’s appeal is considered by the tribunal, it will be considered by the First-tier Tribunal, see ARTG8000.

If either the customer or HMRC are dissatisfied with the decision of the First-tier Tribunal, they may be able to appeal to the Upper Tribunal

  • See ARTG8940 for options following the tribunal decision, and
  • ARTG9010 for tribunal review of its decision.The Upper Tribunal may also, in special circumstances, with the agreement of the parties and the consent of the tribunal, hear cases in the first instance, without the case being heard by the First-tier Tribunal, see

ARTG8060.

These appeals are likely to be those where there are substantial and complex points of law and limited facts to be found.

If either the customer or HMRC are dissatisfied with the decision of the Upper Tribunal they may be able to appeal to the relevant appellate court (Court of Appeal, or Court of Appeal in Northern Ireland, or the Court of Session in Scotland) in certain circumstances, see ARTG9020 and ARTG9030.