MLR1PP11570 - Penalties guidance: Completion of Appeals & Review Submission template

Completion of the template is not expected to be a difficult task. It brings together the Decision(s) made, the evidence relied on and the Decision Maker’s (DM’s) reasoning. To the extent that this has already been done in a penalty notice or pre-penalty notice. it is sufficient to refer to that letter and cross reference it to the folio numbers of the relevant evidence. Any reference to ‘EF’ is referring to the Electronic Folder.

This is the only opportunity the DM will have to explain to the RO why their Decision is correct. The clearer the submission is the easier this will be.

Although the template is primarily designed for staff in direct and indirect tax, most of the sections to be completed are fairly straightforward and self explanatory. However, there are some sections which are not appropriate for MLR purposes and the following notes should help officers decide how to complete those sections:

Section Ref	(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
HMRC Reference	Show MLR registration number
64-8	64-8 not appropriate for MLR purposes. If an agent is acting on behalf of business a letter should be obtained from the business authorising HMRC to discuss the dispute with the agent. Otherwise tick No Box
Disputed decision - Indirect Taxes	(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
Tax Period	Enter date covered by each penalty
Nature	Enter which regulation has been breached with separate line for each breach
OA Reference	Leave blank
Tax disputed	Leave blank
Penalty disputed	Amount of penalty as per the details in the box above relating to the Nature where you have entered which regulation has been breached
Date of issue	Date of penalty notice
Date of visit	Date of final visit to business
Cross Tax Issues	Leave blank. (Should not apply to the AMLS)