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HMRC internal manual

Compliance Handbook

Penalties for Failure to Pay on Time: Appeals against a penalty: Types of appeal and procedure

A person can appeal against the

  • imposition of a penalty, see CH157650, and
  • amount of the penalty, see CH157700.

These appeal rights also allow a person the right to request a review of our decision to impose a penalty and our decision on the amount of the penalty.

For procedural purposes, an appeal is treated in the same way as an appeal against an assessment to the tax concerned. This means that the underlying tax will dictate the procedure for reviews and making appeals.

The person does not have to pay the penalty before an appeal against the assessment of the penalty can be considered.

The Appeals, Reviews and Tribunals Guidance (ARTG2100 for direct taxes and ARTG3000 for indirect taxes) contains full guidance on the review and appeals process.