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HMRC internal manual

Appeals reviews and tribunals guidance

HM Revenue & Customs
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Review of direct and indirect taxes decisions: Introduction: Review process overview

For direct taxes the review process is as follows

If a customer

  • has appealed to HMRC against an assessment or decision but has not yet notified the appeal to the tribunal, and
  • the customer writes to us to ask for a review, thenwe must review the assessment or decision.

If the customer has appealed against a decision and further discussions with the decision maker are not appropriate or have not resulted in settlement of the case, we may offer a review, see ARTG4220.

If the customer does not accept the review offer within the time limit nor notify an appeal to the tribunal within the time limit, then the appeal is treated as settled by agreement.

The customer may still notify an appeal to the tribunal within the time limit, see ARTG2180, provided they have not accepted the offer of a review or asked for a review.

For indirect taxes we will offer the customer a review in the decision letter, see ARTG4230. Any third party who has a right of appeal against a decision (but who has not been offered a review) will be able to ask for a review.

For both direct and indirect taxes there are time limits within which

  • the customer can accept (or third parties may ask for) a review, see ARTG4290, and
  • HMRC must complete the review, see ARTG4690. The customer then has a further period of 30 days from the date of the review conclusion letter within which to appeal to the tribunal.

If we do not complete the review before the time limit has expired we must write and tell the customer

  • that the review is treated as having reached a conclusion, and
  • they may now appeal to the tribunal if they choose. Alternatively we may ask the customer to agree to an extension to the review period. If no extension is agreed the customer may appeal to the tribunal at any time within 30 days of the date of our letter telling the customer the conclusion that review has reached, see also


If the customer agrees with the conclusions of the review, or in any event does not notify an appeal to the tribunal within 30 days, the dispute is resolved in line with the conclusions of the review (subject to the tribunal accepting a late appeal).

In direct taxes the review conclusion letter is treated as a written agreement for settlement under S54(1) TMA 1970. But unlike actual S54 agreements the customer does not have a 30 day period in which they may withdraw from the agreement, (s 49F(3) TMA 1970). If they do not agree they must notify the appeal to the tribunal.