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HMRC internal manual

Securities Guidance

HM Revenue & Customs
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Appeals and reviews: introduction

The tribunal system consists of two tiers, the First-tier Tribunal and the Upper Tribunal. The First-tier Tribunal hears most appeals. Decisions of the First-tier Tribunal may be appealed to the Upper Tribunal provided the appeal is on a point of law and the First-tier Tribunal or Upper Tribunal has given permission.

When we refer to the tribunal in this chapter we mean the First-tier Tribunal.

In this chapter you will find

  • an overview of the appeals and reviews processes for indirect and direct taxes, see SG70200 and SG70300 
  • the review process, see SG71000 
  • guidance on coordinating several different appeals, see SG73000 
  • information about what the tribunal can do in VAT/environmental cases, see SG74000 
  • information about what the tribunal can do in PAYE/NICs cases, see SG74100 
  • guidance on preparing cases for the tribunal, see SG75000 
  • information about the tribunal hearing and the decisions the tribunal can make, see SG76000 
  • guidance about appeals to the Upper Tribunal, see SG77000.

When a decision maker gives a person a Notice of Requirement (NOR), or some other decision in securities work, the person might dispute the decision. The decision maker is the person who signs the NOR or who makes other appealable decisions.

Disputes about securities decisions are treated in the same way as a dispute about an assessment of the tax concerned.

There are different processes for dealing with disputes about

  • indirect tax decisions (VAT and environmental taxes), see SG70200 
  • direct tax decisions (PAYE/NICs), see SG70300.

There is also detailed guidance about reviews and tribunals in the Appeals Reviews and Tribunals Guidance (ARTG). The process for indirect taxes is summarised in ARTG2020 and the process for direct taxes in ARTG2010.

We do not require the person to provide security before an appeal has been heard.

Appeals work takes priority over routine security work due to the tight deadlines that must be met.