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HMRC internal manual

Appeals reviews and tribunals guidance

HM Revenue & Customs
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Reviews and appeals for direct taxes: Appealing against a decision: Grounds of appeal

Any appeal must include the grounds of appeal.

But the grounds given by the customer may not always be valid, either because they are specifically excluded by law or are too vague.

Example 1

An employer wants to appeal against electronic payment because they want to pay by a different method. The law only allows an appeal against electronic payment on certain specific grounds. Those grounds do not include choice of a different payment method. Therefore the appeal is not a valid appeal

Example 2 {.blue6}

John appeals against HMRC’s amendment of his self assessment saying that he was appealing because he thought it was unfair. These are not valid grounds of appeal and so the appeal is not a valid appeal

If the decision maker receives an appeal and the grounds do not appear to be valid, see ARTG2171.

Before rejecting any appeal as invalid, the decision maker should consider also what the independent tribunal would be likely to think, see ARTG2172.

If the customer is not happy with HMRC’s decision but they do not have valid grounds for appeal, they can complain. The decision maker should try to establish from the customer whether their intention is to appeal or complain (or both). A complaint is any expression of dissatisfaction and if in doubt the decision maker should refer it to the relevant complaints team, see ARTG1100.