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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: Reviewable decisions

An HMRC decision is reviewable, that is, the customer is entitled to a review by HMRC of the decision if the customer has a right of appeal to the tribunal, see ARTG2040.

In direct taxes the customer must also have sent an appeal to HMRC.