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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Introduction: Decisions that are not reviewable

The following decisions are not reviewable

  • decisions where there is no right of appeal, see ARTG2040
  • decisions about whether to allow a late review
  • decisions about whether to allow late appeals
  • refusals to allow postponement or hardship applications
  • conclusions of review
  • simple assessments.

There are a number of matters that the tribunal considers on application or referral, for example closure applications, information notice applications (Part 1 Schedule 36 FA 2008), applications for daily penalties (Para 40 Schedule 36 FA 2008).

Although these are considered by the tribunal they are not appeals and they are not within the scope of the review provisions. See ARTG7500 onwards, for further guidance on applications to the tribunal.