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HMRC internal manual

Appeals reviews and tribunals guidance

Review and appeals for direct taxes: Appealing against a decision: Customer appeals and HMRC offer a review

If the decision maker does not think that further discussions are appropriate, or if they do not lead to agreement, the decision maker should write to the customer giving HMRC’s current view of the matter and offer them a review, see ARTG4220.

Where a customer disagrees with a Simple Assessment they should be advised to raise a query under s31AA TMA1970. There is no right of review to a simple assessment until HMRC have given a final response to the query and the customer has appealed that response.