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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for indirect taxes: Appealing against a decision or assessment: Customer asks for extension of review acceptance or appeal period

Decision makers must offer customers a review within the decision letter. The customer may accept the review offer or appeal to the tribunal within 30 days of the date of the letter. Decisions falling under s14 Finance Act 1994 allow a person 45 days to send a notice requiring a review to the Commissioners. This includes certain Customs Duties, Agricultural Levy and Excise Duty decisions. Alternatively the customer may ask for an extension to the period for accepting the offer of a review or making an appeal, for example if they have further information or arguments to put to the decision maker.

If the customer asks for an extension, the decision maker may grant it. But the customer must ask for an extension of time before the end of the 30 day acceptance period in order that we can action the request in time, as we must write to the customer granting an extension within 30 days of the date of the decision letter.

The extension may be for 30 days from

  • the date of HMRC’s letter, or
  • any other date set out in the letter, or
  • any other date set out in a subsequent letter

If a customer accepts an offer of review, they may not appeal to the tribunal until they are told of the review conclusion or the review period has expired.

If the customer asks for an extension out of time we may treat that as a late review request. Alternatively, they can ask the tribunal to accept a late appeal notification. We have no power to extend the appeal/review time limit after it has ended.

See ARTG3080 for action on receipt of further representations from the customer.