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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: arranging for a review: review arrangements

Once the customer has asked for a review of the disputed decision, or accepted our offer of a review, the decision maker should prepare a report for the review officer. The report should clearly summarise

  • the decision the review officer is required to review
  • the facts
  • the relevant legislation and guidance
  • the decision maker’s reasoning
  • the customer’s argument and evidence, and
  • the decision maker’s argument and evidence

The decision maker should make sure that they provide all information necessary for the review officer to carry out a review. Business areas may provide a template for this purpose. Decision makers should check their business area’s web pages, or ask their Appeals and Review Unit to see whether their business area provides a template.

They should send the summary and the case papers to the relevant review officer and record on the computer system for the relevant tax regime the date that they sent the case to the review officer for review.

They should also highlight the date they notified the customer of their view of the matter, see ARTG4690, or the date we received their acceptance of the review offer, see ARTG4690, or the date they decided to undertake the review, see ARTG4300, so that the review officer is aware of the amount of time that has expired since the commencement of the 45 day review period.

It may be that the required information was clearly set out in the decision letter, or a subsequent letter giving HMRC’s current view of the matter, in which case a summary will not be necessary and the report can refer to the relevant letter.

Business units may have a template form for sending cases to the Review Team to carry out a review. The decision maker should check local procedures and use a template if available.