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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for indirect taxes: Appealing against a decision or assessment: Requests and appeals by third parties

Where a third party has a right of appeal against a decision by HMRC, they may require HMRC to review their decision by writing to HMRC within 30 days of them becoming aware of the decision. But if either they or the customer has already appealed to the tribunal, HMRC may not carry out a review.

The third party time limits described in ARTG3120 also apply to appeals and review requests by third parties.

Where the third party is the recipient of a supply they should liaise with the supplier to agree a common position on which to contest the appeal.