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HMRC internal manual

Appeals reviews and tribunals guidance

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HM Revenue & Customs
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Reviews and appeals for indirect taxes: Appealing against a decision or assessment: Time limit for making an appeal

The time limit for a customer who receives a decision to appeal against the decision to the tribunal is

  • 30 days from the date of the document telling the customer of the decision (or where the time limit was extended, the date given in the letter granting them the extension, see ARTG3060, or
  • where a review has taken place, 30 days from the date of the conclusion of review letter, see ARTG4820, or
  • where HMRC do not complete the review within the 45 days or other agreed period (the “review period”), any time from the day after the review period expired to 30 days from the date of the document telling the customer of the decision that the review is treated as having reached, see ARTG4850, or
  • 30 days from the date HMRC decided not to carry out a review when the customer asked for a review outside the time limit and we refused, see ARTG4300.

And the time limit for a third party to appeal to the tribunal is

  • 30 days from the date the third party became aware of the decision, or
  • where HMRC have granted an extension to the period for accepting a review or appealing to the tribunal, 30 days from the date of the notice granting the extension or 30 days from any other date given in the notice or a further notice
  • where a review has taken place, 30 days from the date of the conclusion of review letter, see ARTG4820, or
  • where HMRC do not complete the review within the 45 days or other agreed period (the “review period”), any time from the day after the review period expired to 30 days from the date of the document telling the customer of the decision that the review is treated as having reached, see ARTG4850, or
  • 30 days from the date HMRC decided not to carry out a review when the customer asked for a review outside the time limit and we refused, see ARTG4300.

If the customer agrees with the conclusions of the review and/or does not appeal to the tribunal within 30 days, the dispute is resolved in line with the conclusions of the review (subject to the tribunal accepting a late appeal).

The customer cannot appeal to the tribunal during the review period. They must wait until we send them our review conclusions, see ARTG4800 onwards, or the end of the review period. If a customer does appeal to the tribunal during the review period, see ARTG4640.