ARTG4680 - 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 (see ARTG3310).
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.