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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Conclusion of the review: Action to take

Whatever the outcome of the review the review officer will write to the customer and give their conclusions, sending a copy to the decision maker, but see ARTG4630 where the appeal is settled following the customer providing new information.

Where an agent is acting the reviewing officer should write to the customer and send a copy of the letter to the agent.

The letter must

  • tell the customer the review officer’s decision
  • explain the reasons for the review officer’s decision, and
  • say what will happen now.

Also, if the conclusion upholds or varies the decision the letter must

  • explain the options available to the customer (appeal to the tribunal if the customer disagrees with the conclusion)
  • explain the relevant time limits
  • explain the implications for any ongoing postponement or other suspension of tax, and
  • explain the consequences if the customer does not take any action.

This is described in this guidance as the ‘conclusion of review letter’.

It is important that a full and clear explanation of the decision is given because if the customer is satisfied that the review officer has fully and objectively reviewed their decision and has explained the reasons for their conclusions, the likelihood of an appeal to the tribunal may be reduced.

If the customer decides that they do want the matter to be considered by the tribunal, then they can be satisfied that they understand the reasons for our decision.

At the end of the review the review officer should send any hard copy evidence back to the decision maker.