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HMRC internal manual

Appeals reviews and tribunals guidance

First-tier and Upper Tribunals: Preparing for tribunal: Role of Solicitors office

The Solicitor’s Office is responsible for

  • advising if asked whether HMRC should defend a case at tribunal in consultation with other Departmental stakeholders (indirect taxes)
  • preparing and presenting HMRC’s case at tribunal at

    • First-tier hearings - complicated cases (whether or not allocated to the Complex category by the Tribunals Service)
    • Upper Tribunal and relevant appellate court hearings, working with counsel where appropriate
  • providing legal advice to tribunals caseworkers
  • consulting with tribunals caseworkers to decide whether HMRC should

    • make an application to the tribunal for directions, or to contest an application by the customer
    • appeal against a tribunal decision
  • appointing and instructing counsel if necessary, to present HMRC’s case.