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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for indirect taxes: Payment of tax pending the out come: Hardship and security after the tribunal decision

Where a customer has appealed to the tribunal against an HMRC decision and the tax was not paid because the customer was granted hardship or a certificate for security, once the tribunal has decided the matter the customer must pay any tax due.

If the tribunal finds in the customer’s favour HMRC must repay any overpaid tax. But see ARTG8930where there is an appeal to the Upper Tribunal or the relevant appellate court.