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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: Payment of tax pending the outcome: Following appeal to the tribunal

If the customer appeals to the tribunal, the tribunal may only hear the appeal if the disputed tax has been paid to HMRC, unless

  • the customer provides acceptable security (excise and customs duties), or
  • the customer applies for tax not to be paid because payment of it would cause them hardship and HMRC or a tribunal accept their application, see ARTG3330, (all indirect taxes)Penalties, interest and surcharge do not have to be paid before an appeal can be heard by the tribunal, but any assessment of tax that triggered the penalty/interest/surcharge must be paid.