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HMRC internal manual

Appeals reviews and tribunals guidance

HM Revenue & Customs
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Restoration decisions: Arranging for a review: Reviews

If a customer disagrees with a restoration decision, see ARTG6010, by HMRC, they can require HMRC to carry out a review by writing to HMRC within the time limit, see ARTG6240.

If the customer asks for a review, we have 45 days in which to carry out the review (Section 15(2) Finance Act 1994). If we do not notify the outcome of the review within 45 days of the date the review was required the decision is treated as confirmed.

If the customer disagrees with the outcome of the review they have 30 days within which to appeal against the review conclusion to the tribunal, see ARTG6540.

The optional review processes introduced in April 2009, see ARTG4000 onwards, does not apply to restoration decisions.

Restoration decisions are the only decisions where an HMRC review must be carried out before the customer can appeal to the tribunal. But see also ARTG6600 where the restoration decision is linked to another decision.

If a customer wants to challenge the seizure itself see ARTG6010.