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HMRC internal manual

Debt Management and Banking Manual

Interest: handling interest objections and enquiries: DTO action: complaints

The IRU is involved in two types of complaint cases:

  • cases where a customer is unhappy with the IRU’s decision on an interest objection
  • tier one or two complaints wholly or partly about interest.

Cases where a customer is unhappy with the IRU’s decision on an interest objection

The IRU will already have written to the customer, probably more than once, to try to resolve the dispute about the interest. If the customer is still dissatisfied, the IRU will tell them to pass their concerns through the complaints process.

Occasionally, it will not be appropriate to ask them to start at the bottom of the complaints process but instead to contact the tier two team, not tier one.

It is not always clear which complaints team should take a case on, but generally speaking the team who has the bulk of the complaint should take it forward. For example, if mishandling of the underlying tax caused an unnecessary build up of interest, then the complaints team responsible for the tax will usually take the case, to make sure that concerns about the tax itself have been handled properly and compensation issues addressed. Complaints Teams should consider each case on its merits and decide who will take the lead.

Tier one or two complaints wholly or partly about interest

These are cases already working with Complaints Teams before interest becomes, or is identified as a concern. Complaints Teams should make sure they follow the steps in this guidance where interest is a factor in a customer’s complaint.

Unlike local interest handlers, complaints teams sometimes will not want to wait until the underlying tax has been fully paid (and interest stops building up), before sending a case to the IRU. To help resolve the complaint, we will aim to issue a decision in principle in these cases. If we identify possible grounds for giving up interest, we will ask you to tell us when the interest becomes final so that the remission can be dealt with.

The IRU aim to give you our decision within ten working days. A form of words will be provided for you to reply to customers yourself, so that they have only one contact point for their complaint.

Ideally, you should hold off replying to other aspects of the complaint until you have a decision on the interest, but if time is short you can send out a partial reply and say you are still considering the interest and will write again shortly. Don’t tell customers about the IRU’s involvement in their complaint.