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HMRC internal manual

Self Assessment Manual

Appeals, postponements and reviews: appeals: grounds of appeal

Revenue assessments and amendments

Appeals against a Revenue assessment (SAM20130), Revenue amendment (SAM21020) or Jeopardy amendment (SAM21010) will normally be made on the grounds that

  • The assessment or amendment is incorrect


  • The actual liability has yet to be determined

Filing penalties and payment penalties (known as surcharge for tax years 2009-10 and earlier)

There are two possible grounds of appeal against a penalty relating to the late submission of an SA return, or penalty (surcharge for tax years 2009-10 and earlier) for late payment of tax

  • Fact - for example, the return was delivered to HMRC on or before the filing date, the payment was made on time, or in late payment penalty cases (surcharge cases for tax years 2009-10 and earlier), where there is an agreed time to pay (TTP) arrangement already in place for that year
  • Reasonable excuse - for example, the taxpayer was prevented by ill health from submitting the tax return or making a payment

To help you to decide whether or not an appeal on the grounds of reasonable excuse may be accepted, see subject ‘Reasonable Excuse’ (SAM10090).

If you are in doubt as to whether you should accept an appeal on the grounds of reasonable excuse you should contact the Interest Review Unit in Cumbernauld for advice.

Further guidance

More detailed guidance concerning appeals against specific charge types is contained in the subjects

  • ‘Appeal against a fixed automatic penalty’ (SAM10080)
  • ‘Appeal against miscellaneous penalties / surcharge (for tax years 2009-10 and earlier)’ (SAM10100)
  • ‘Appeal against a Revenue assessment’ (SAM10110)
  • ‘Appeal against a Revenue amendment’ (SAM10120)

More detailed guidance about reasonable excuse can be found in the Compliance Handbook (CH155600)