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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for direct taxes: Appealing against a decision: What decisions can be appealed against

The law allows customers a right of appeal against most HMRC decisions, including the following

  • an amendment of a self assessment or partnership statement by HMRC
  • an assessment to tax which is not a self assessment where a return has been completed for the period covered by the assessment
  • a simple assessment where the customer has raised a query under s31AA TMA1970 and been given a final response to that query
  • the refusal or removal of gross payment status in CIS cases
  • the imposition of a penalty or an interest or penalty determination
  • a decision relating to a person’s liability or entitlement to pay National Insurance Contributions
  • a direction relieving an employer of liability for under-deducted PAYE
  • a determination relating to an employer’s failure to operate PAYE
  • certain information notices, such as Para 1 Schedule 36 FA 2008, except where approved in advance by the tribunal
  • an appeal against a decision not to suspend a penalty, see CH84050 
  • a conclusion contained in an ITSA notice, or an amendment of an assessment made by ITSA or CTSA partial or final closure notice
  • a discovery assessment to tax where a tax return has not been completed for the period covered by the assessment
  • appeals against claims decisions OTA75/Schs 5 - 8.

This list is not exhaustive.

A customer may appeal to HMRC against a jeopardy amendment; see EM1955, during an enquiry into their self assessment. But they are not entitled to a review or to notify their appeal to the tribunal until the enquiry into the matters to which the amendment relates has been closed, see EM1955.

If a customer appeals against a jeopardy amendment during an enquiry into their self assessment they may apply to postpone payment of some or all of the tax charged in the usual way, see ARTG2510.