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HMRC internal manual

Decisions and appeals for National Insurance Contributions and Statutory Payments

Formal decision covers dispute decision

Where you are giving an opinion for which a decision could be issued which carries a right of appeal, the opinion letter should include the following text

If you disagree with what I have said in this letter write and tell us why you think it is wrong. We will consider what you tell us. If we are unable to reach agreement we will send you a formal notice of our decision and tell you what your options are if you disagree with the notice.

For opinions about statutory payments see SPD13000 for more information about what should be included in the opinion letter.

Where you cannot reach agreement or the customer asks for a decision, you must issue a notice of decision. If the customer appeals to HMRC against that decision

  • you can offer a review, or
  • the customer can ask for a review of the decision, or
  • they can notify their appeal to the tribunal.

See DANSP12000 for information about issuing decisions. Wherever possible, try to get all the relevant facts and consider those facts before issuing a notice of decision.