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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 (indirect taxes)

While the decision is the subject of a dispute HMRC may suspend any disputed tax pending review.

If the decision maker has not already done this, and the customer wants payment of any tax to be suspended, the review officer may arrange for this while the review is carried out.

The suspension should be removed at the end of the review, and, if appropriate, any assessment should be amended or reissued depending on the conclusions of the review.

If the customer does not agree with the conclusions of the review they can appeal to the tribunal but they must then pay any tax due subject to any hardship application, see ARTG3330.