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HMRC internal manual

Appeals reviews and tribunals guidance

First-tier and Upper Tribunals: the tribunal hearing: conduct of the hearing

Guidance on the etiquette to be observed at tribunal is at CH265170.

The normal order of procedure at a tribunal hearing where the onus of proof is on the customer (for example cases other than those where HMRC could take criminal proceedings and some penalty cases) is that the customer will present their case first.

HMRC will then present its case and the customer will have a further opportunity to respond. If the onus of proof is on HMRC then we would expect to be asked to present our case first.

At the end of the hearing the tribunal may ask the parties to retire while they discuss the case. The judge of the tribunal may then announce their decision.

In more complicated cases the tribunal members may consider their decision at length and write to the parties with their decision in due course. But all tribunal decisions will be confirmed in writing by the tribunal, see ARTG8910.