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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 there is no right of review. If the customer believes that a Simple Assessment is or may be incorrect, then they should be advised to raise a query under s31AA TMA1970.