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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Introduction: Scope and limitations of the review

The nature and extent of the review is to be determined by the review officer. It must be proportionate and will vary according to

  • the complexity of the case
  • the steps taken to reach the decision, for example if specialist advice has already been obtained
  • the steps taken so far to resolve disagreement about the decision.