Set-offs - S130 FA2008: objections to set-off
There is no formal appeal against set-off but HMRC have undertaken to consider the circumstances where a taxpayer raises concerns after a set-off has been made.
There are no hard and fast rules on this and you should consider such objections on a case by case basis.
Where HMRC have made an error the set-off must be reversed, otherwise there will be very few circumstances in which you would need to reverse the set-off.
Contentious or unusual circumstances
If you feel that reversal of set-off may be necessary due to contentious or unusual circumstances contact the Corporate Finance, Tax Accounting Policy (TAP) Team (Corporate Finance) for advice.
Cases of doubt or difficulty
Refer any other cases of doubt or difficulty to your manager.