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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for direct taxes: appealing against a decision: liaison with specialist offices

In the cases listed below, a technical specialist should be involved when it is clear that the customer intends to notify an appeal to the tribunal.

If the decision maker becomes aware that the customer has, or intends to notify an appeal in any of the following categories to the tribunal, they should refer it to the technical specialist or HMRC accountant, as appropriate, straightaway for consideration. The specialist may ask the decision maker to work the case subject to specialist guidance.

  • residence status of an individual
  • domicile of an individual
  • appeals relating to the meaning of “usual place of abode” or “liabilities of prescribed persons” in relation to the Non-resident Landlords Scheme regulations, or
  • shares and asset valuation

If the decision maker thinks that specialist advice is necessary in any other case they should refer it to the specialist for consideration once they become aware that the customer intends to notify an appeal to the tribunal.

Criminal investigations

If the customer disagrees with a decision by HMRC in a case where there is an ongoing criminal investigation, the decision maker should contact Criminal Investigations for advice before taking any action.

Accountancy issues

See ARTG2190 about seeking advice from accountancy specialists.