HMRC internal manual

Appeals reviews and tribunals guidance

ARTG2150 - Reviews and appeals for direct taxes: Appealing against a decision: Who can make an appeal

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

An appeal may be made by

  • the person named in the decision
  • an individual in their capacity as a personal representative or trustee
  • a partner acting on behalf of a partnership
  • an authorised agent acting on behalf of the customer.

Throughout this guidance, any reference to a customer should be taken as also referring to their agent or other person eligible to appeal against the decision on their behalf.

But it is important to remember that the customer must be informed directly of any decision that affects their appeal rights, including a letter telling them of

  • HMRC’s current view of the matter and offer of review and current view of the matter, see ARTG2212 
  • HMRC’s current view of the matter, see ARTG2213, following the customers request for review, even if the request came from their representative
  • the conclusion of HMRC’s review if the review has been completed within the time limit, see ARTG4820 
  • the conclusions HMRC is treated as having reached if the review has not been completed within the time limit, see ARTG4850.

A person who has been subject to a bankruptcy order does not have any legal standing to make or continue with an appeal – only the trustee in bankruptcy may do so.