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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for indirect taxes: Appealing against a decision or assessment: Before the decision

For most tax decisions that will result in an assessment, it is good practice for the decision maker to write to the customer giving their views before formally sending the customer their decision (a pre-decision letter), see VAEC6010.

When they receive a pre-decision letter, the customer may provide further information or explanation and ask for further discussions on the matter, following which the decision maker may be able to close the case without formally notifying the customer of their decision.

If, following further discussions the decision maker is unable to agree with the customer, they should send a decision letter, see ARTG3050, to the customer to formally tell them their decision, as appropriate.