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HMRC internal manual

Other Non-Statutory Clearance Guidance

HM Revenue & Customs
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Reviews and appeals: direct tax appealable decisions

It is not likely that direct tax decisions made by clearance teams will carry a right of appeal. There is no direct tax equivalent to section 83(1)(b) [for VAT], and it is unlikely that clearance teams will issue closure notices or assessments, amend returns or refuse claims.

If you are not sure about whether your decision is appealable, contact Tax Administration Advice (TAA)