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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for direct taxes: Payment of tax pending the outcome of an appeal: Postponement - what happens after the tribunal decision

Where a customer has appealed to the tribunal against an HMRC decision and the disputed tax has been postponed, once the tribunal has decided the matter the customer must pay any tax due once the tribunal has decided the matter. If the tribunal finds in the customer’s favour HMRC must repay any overpaid tax.

The customer (or HMRC) must pay (or repay) any tax due as a result of the tribunal’s decision. But see ARTG8930 where there is an appeal to the Upper Tribunal or the relevant appellate court.