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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Carrying out a review: customer appeals to the tribunal during the review

The customer cannot appeal to the tribunal and the tribunal cannot consider an appeal during the review period.

If the decision maker or review officer receives information that the customer has appealed to the tribunal while a review is being carried out. They should tell the Tribunals Service Central Processing Centre that a review is ongoing and ask the tribunal to explain to the customer their appeal notification is invalid because an appeal cannot be made or notified to the tribunal while a review is ongoing.

The decision maker, or review officer as appropriate should also contact the customer and explain that an appeal cannot be sent to the tribunal while a review is ongoing and that the review officer will write with their conclusions at the end of the review period.

After the review has concluded, if the customer does not agree with those conclusions, they may then appeal to the tribunal. See ARTG2410 for direct taxes and ARTG3130 for indirect taxes.