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HMRC internal manual

Excise Statutory Interest Manual

Processes and procedures: appeals and reviews

Paragraph 9A of Schedule 5 to the Finance Act 1994 allows an appeal to the First Tier Tribunal, against decisions relating to any liability of HMRC to pay statutory interest, and the amounts of statutory interest paid, in accordance with Part 2 of Schedule 3 the Finance Act 2001.

HMRC must offer a statutory review of all appealable decisions, the taxpayer has 30 days within which to take up the offer or appeal direct to the Tribunal.

If the taxpayer takes up the offer of a review and the outcome of that review confirms the original decision, the taxpayer will have a further 45 days in which to appeal.

The Appeals Reviews and Tribunals Guidance ARTG sets out in detail the procedures you should follow if a taxpayer or their representative requests a review or appeals against any appealable decision.