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HMRC internal manual

Excise Civil Penalties Manual

Reviews and appeals: Payment of the penalty in dispute

During the review, debt recovery action should be suspended until the outcome is known. It is important to keep the Accounting Centre and any Debt Management Unit that may be involved up to date on case progress.

If the taxpayer appeals to the tribunal, it is not necessary for the penalty to have been paid before the tribunal will hear the appeal, but the tax on which any penalty is based must have been paid (unless we or the tribunal has accepted that to do so would cause them hardship).