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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Information & inspection powers: information notices: appeals: appeal procedures

Appeals against information notices must always follow the direct tax appeal and review procedure regardless of whether the compliance check relates to a direct or an indirect tax position. The HMRC appeal and review procedure is described in full in the Appeals, Review & Tribunals Guide (ARTG).

If a person wishes to appeal against an information notice they must send their appeal to the decision maker. For an information notice, the decision maker is the person who gave the notice.

An appeal must

  • be in writing
  • reach HMRC within 30 days of the date on which the information notice was received, but see also ARTG2240 about late appeals
  • be addressed to the officer of HMRC who gave the information notice, and
  • state the grounds of appeal.

The rules in Part V of the Taxes Management Act 1970 [Appeals and other proceedings] apply to an appeal against an information notice.

This means that the appeal can be settled by agreement between HMRC and the appellant.

If the dispute is not resolved either by discussion or following a review, the appellant may notify their appeal to the tribunal to decide the matter, see CH24100. The tribunal’s decision is final. This means that both the appellant and HMRC must abide by its decision.

For further guidance on appeal rights against

  • a taxpayer notice see CH24360
  • a third party notice see CH24380
  • an identity unknown notice see CH24400
  • an identification notice, see CH24410.