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HMRC internal manual

Appeals reviews and tribunals guidance

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HM Revenue & Customs
Updated
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First-tier and Upper Tribunals: Preparing for tribunal: Basic cases

The customer’s notice of appeal must

  • contain the information set out in ARTG8210 above
  • contains copies of any written record of any decision appealed against, and any statement of the reasons for that decision that the appellant has or can reasonably obtain
  • say whether they would agree to the case being considered without a hearing if the tribunal thinks it is appropriate.

Once the tribunal has received this information it will usually make arrangements for the hearing.

In most cases there will be no further communication between the parties before the hearing, for example there is generally no requirement for HMRC to provide a statement of case, although the tribunal can decide to request further information from the parties, including a statement of case.

But if there are any new arguments we intend to raise at the hearing that the customer is not aware of, tribunal rules require us to write to the customer or their representative telling them of the new arguments as soon as possible after becoming aware that this is the case, and in enough detail for the customer to respond to those arguments at the hearing.