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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Arranging for a review: HMRC offer of a review (indirect taxes)

HMRC must offer the customer a review of any appealable decision or assessment.

If the customer is notified of HMRC’S decision by computer-generated output, such as a notice of assessment, the offer of a review will be contained in the accompanying notes.

If the decision maker tells the customer of their decision by sending them a decision letter the decision letter must include an offer of review, see ARTG3050.

The decision letter should say clearly what the customer should do if they disagree with the decision. They can

  • appeal to the tribunal, or
  • accept the offer of review

within the time limit, see ARTG3120.

The decision letter should explain clearly who the customer should write to if they want to accept the offer of a review, which may be the decision maker or the review team in the business area, and invite representations from the customer in support of their position, see ARTG4620.

The decision letter should also explain that if the customer neither accepts the offer of a review nor appeals to the tribunal, the matter will be final. If the customer does not accept the review but sends in further information see ARTG3080.

See ARTG4300 about late acceptances of a review offer and ARTG3160 about late appeals.