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HMRC internal manual

Appeals reviews and tribunals guidance

First - tier and Upper Tribunals: Preparing for tribunal: Groups of related cases: Payment of tax

The normal rules for payment of disputed tax will apply to both lead and stayed cases.

Postponement (direct tax)

The progress of the appeals in related cases is not affected by whether or not the disputed tax is postponed; see ARTG2510 in any or all of the related cases. While an appeal is ongoing tax will be payable unless the tax has been postponed, see ARTG2500.

Hardship (indirect tax)

Before the tribunal may hear a customer’s appeal, any disputed tax must have been paid to HMRC, or HMRC or the tribunal must have agreed that payment is not required due to the customer suffering hardship, see ARTG3330.

Where one (or more) of a number of related cases cannot pay the disputed tax, they may make a hardship application in the usual way. But their appeal cannot be considered together with the other related cases and stayed until either the disputed tax has been paid, or HMRC or the tribunal has agreed that hardship applies.

See ARTG9060 about payment of tax where there is a further appeal.

National Insurance Contributions

Where a customer has appealed against a National Insurance Contributions decision HMRC does not require the customer to pay the NICs. But if they wish to limit the interest accruing, they may pay some or all of the NICs charged.