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HMRC internal manual

Compliance Handbook

Penalties for VAT and Excise Wrongdoing: Appeals against a penalty: Types of appeal and procedure

A person can ask for a review of or appeal against

  • the imposition of a penalty, see CH97200
  • the amount of any penalty, see CH97250.

An appeal is treated for procedural purposes in the same way as an appeal against an assessment to the tax or duty concerned, except in respect of a matter expressly provided for by FA08/SCH41. This means that the underlying tax or duty regime will dictate the procedure for reviews and appeals.

Appeals will usually be heard by the First-tier Tribunal.

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