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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Introduction: The review process



From 1 April 2009 customers have a legal right to have appealable tax decisions or assessments reviewed by another HMRC officer before appealing to the tribunal.

If the decision relates to the restoration of seized goods different rules apply and this part of the guidance does not apply to these reviews, see ARTG6200 onwards for restoration decisions guidance.

So if customers dispute an HMRC decision, in addition to discussing the matter with the decision maker they may, depending on the circumstances



  • ask for a review (direct taxes and indirect taxes third parties), or
  • be offered a review (direct and indirect taxes), or
  • appeal to the tribunal.

But they cannot appeal to the tribunal while a review is being carried out, see ARTG4640.

Where a customer disagrees with a Simple Assessment there is no right of review. If the customer believes that a Simple Assessment is or may be incorrect, then they should be advised to raise a query under s31AA TMA1970.