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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Carrying out a review: Payment of tax during the review (direct taxes)

If the customer has made an application for postponement and the decision maker has accepted it, see ARTG2510, they will not be required to pay the disputed tax. But see ARTG11030about interest on unpaid tax.

In cases where the matter in dispute relates to entitlement to gross payment in the construction industry, HMRC will not take any action in relation to the gross payment while the case is under review.

If a period during which the customer has to demonstrate entitlement to gross payment has started when the review takes place, the period will stop while the review is carried out and restart on the date the review is completed.