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HMRC internal manual

Non-statutory Clearance Guidance

Reviews and appeals: what are appealable decisions

New processes for reviews and appeals started on 1 April 2009.

From 1 April 2009 all letters we issue which include an appealable decision must contain paragraphs on the relevant process for review and appeals. Some clearances will contain appealable decisions.

Across the taxes, decisions which impose a requirement to pay tax or penalties or refuse or reduce claims are normally appealable. It is not likely that clearance teams will issue such decisions. However the law provides a right of appeal against a number of other decisions, and some of these may be made by clearance teams.