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HMRC internal manual

Appeals reviews and tribunals guidance

HM Revenue & Customs
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Reviews and appeals for indirect taxes: appealing against a decision or assessment: who can make an appeal

Appeal made by

An appeal may be made by

  • the person who is the subject of the decision, or
  • their personal representative or trustee

In some taxes other interested parties may also be able to appeal. Some examples are listed below - but this list is not comprehensive.


  • the recipient of a supply can appeal if they have sufficient interest in maintaining the appeal, in certain circumstances (if the decision maker receives an appeal from a recipient, they should seek advice if necessary from their Appeals and Review Unit as to whether they should accept the appeal)
  • one or more of the partners, if the taxable person is a partnership
  • one or more VAT group members

Excise or Customs

  • a person who is liable to pay any excise or customs duty or penalty as a result of the decision may appeal that decision
  • a person on whom conditions or restrictions are imposed by an excise or customs decision may appeal (s 16(2A)(C) FA 1994).

Environmental taxes, IPT and APD

Any person who is or will be affected by any appealable decision may appeal it.

APD - FA 1994 s13A - 16 and Sch 5.9

IPT - FA 1994 s59-60

Climate Change Levy - FA 2000 Sch 6 121-123

Landfill tax

A developer, or a controller of a landfill site may appeal in certain circumstances, see the general guide to landfill tax.

Throughout this guidance, any reference to a customer should be taken as also referring to their agent, or other person eligible to make an appeal against the decision or assessment on their behalf.

Landfill Tax - FA 1996 s54-56

Third party appeals

See ARTG3190 where a third party who is affected by an indirect tax decision but is not the person receiving the decision wants to appeal or ask for a review.