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HMRC internal manual

Securities Guidance

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HM Revenue & Customs
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Appeals and reviews: reviews: what a review involves

Reviews are carried out by review officers who have experience of the subject matter of the appeal but are independent of the decision maker.

A review involves the review officer taking a fresh look at the decision which is under review. This may or may not be in the light of new evidence, but it must be done in an objective, independent and balanced way if the person is to have confidence in the system.

The review officer will uphold, vary or cancel the original decision, thereby avoiding a formal appeal to tribunal, see SG71300.

We impose no pre-conditions that a person must meet, for example by providing security, for a review of the decision to require security other than the requirement to accept the review offer within 30 days (indirect taxes only).

Guidance on reviews and appeals for direct taxes (PAYE/NICs) is at ARTG2100.

Guidance on reviews and appeals for indirect taxes (VAT and environmental taxes) is at ARTG3000.

Guidance on reviews of decisions for both direct and indirect taxes is at ARTG4000.