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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Security instead of payment

Customers may provide security by way of bond or guarantee for the tax on excise goods produced or held by them. Usually this security will be sufficient to cover the tax due. But where it is not the customer must pay the tax due or give further security before the appeal can be progressed, except where the customer makes a hardship application.

The customer’s appeal may go ahead without the duty having been paid, see ARTG3320, if HMRC provide a certificate to the tribunal, see ARTG15000. The certificate should state that

  • HMRC hold adequate security to cover the tax involved, or
  • HMRC have accepted an amount of lesser security (where HMRC have accepted a hardship application) that we consider to be appropriate

If HMRC refuse to provide the customer with a certificate the customer may apply to the tribunal to decide what security would be reasonable for HMRC to accept.