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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Arranging for a review: Who carries out reviews

HMRC have given a commitment to Ministers that the statutory review to which customers are entitled will be conducted by someone outside of the line management chain of the decision maker.  Reviews must therefore be carried out by review officers. Review officers have experience of the subject matter of the appeal but are independent of the decision maker and the decision maker’s line management. This allows the review officer to remain as objective as possible.

The review should be proportionate and effective.

For example, a review of a decision on a complex legal point is very likely to be more extensive than a review of a disputed fixed filing penalty decision.

Although different types of review are appropriate in different circumstances, each review officer must follow the principles of review, see ARTG4080.

Review officers in larger business units work in teams in Appeals Units, see ARTG4320.