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HMRC internal manual

Non-statutory Clearance Guidance

Template letters: indirect tax appealable decision

Please ensure that the text of this letter is correctly inserted into the appropriate letterhead for your line of business and carefully adapted as indicated in the body of the letter.

Caseworker or CCM’s address, plus phone, email

For the attention of

Business or Advisor’s name & address


Our ref: [Any reference number allocated locally.]

Your ref: [Any customer reference from their correspondence]

Clearance ref: [Clearance reference allocated by Southend]

Dear …

Clearance application received… [date received in HMRC - day 1 of the 28 days]

Thank you for your recent correspondence dated.

[Description of decision]

[Explanation of reasons for decision, including

  • facts
  • reasons for the decision
  • law supporting the decision-if appropriate
  • tax due as a result of decision - if applicable]

If you have any further information that you want me to consider, please send it to me now. I will consider the new information you send and, if appropriate, revise my decision.

If you do not agree with my decision, you can

  • ask for my decision to be reviewed by an HMRC officer not previously involved in the matter, or
  • appeal to an independent tribunal

If you opt for a review you can still appeal to the tribunal after the review has finished.

If you want a review you should write to [review team] at [address] within 30 days of the date of this letter, giving your reasons why you do not agree with my decision. We will not take any action to collect the disputed tax while the review of the decision is being carried out.

If you want to appeal to the tribunal you should send them your appeal within 30 days of the date of this letter.

You can find further information about appeals and reviews on the HMRC website or you can phone the number on this letter. You can find out more about tribunals on the Tribunals Service website or you can phone them on 0845 223 8080.

Please read the section, ‘When you can rely on a clearance’ in our guidance for full information on when you can rely on a clearance response from us.

This clearance letter reflects HMRC’s view of the tax consequences of the specific [transaction/circumstances] as set out in your letter dated [xxx].  You [your client] are entitled to act on the basis of our view or on the basis of your [their] own view of the appropriate tax treatment and self-assess accordingly. 

The view expressed in this letter is not for general application.  If you [your client] wish to apply this ruling more generally, you should discuss this with HMRC.  This ruling only relates to the specific circumstances and facts that you have let us know about, and to HMRC’s current view of how the legisaltion applies, which HMRC specifically reserves the right to change in the future.  Where you [your clients] apply this view more generally, or where HMRC suspect tax avoidance, HMRC reserves the right to review the tax consequences of these transactions and to form another view.

If you have any further queries regarding this matter, please do not hesitate to contact the address shown above quoting our reference number.

Yours sincerely

Name of caseworker/CCM

Title/role within HMRC

Direct line phone number