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HMRC internal manual

Appeals reviews and tribunals guidance

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HM Revenue & Customs
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First-tier and Upper Tribunals: Outcome of the tribunal proceedings: Customer does not accept the decision of the tribunal

If the customer does not accept the decision of the tribunal and wants to appeal, the same procedures apply to the customer as apply to HMRC. The customer must apply to the tribunal for review or permission to appeal to the Upper Tribunal (or relevant appellate court if the appeal is against a decision of the Upper Tribunal).

The Clearing House will tell the tribunals caseworker (direct taxes) or Solicitor’s Office (indirect taxes or restoration decisions) if the customer asks either tribunal for permission to appeal.

If permission is granted and the customer appeals the tribunals caseworker (direct taxes) or Solicitor’s Office (indirect taxes and restoration decisions) should update their records and tell other interested parties, such as the decision maker, technical specialists and Solicitor’s Office.

The Solicitor’s Office will usually take over responsibility for the case at this stage in all tax cases and begin preparing the case for hearing by the Upper Tribunal or relevant appellate court, see ARTG8410.