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HMRC internal manual

Senior Accounting Officer Guidance

Appeals: overview

The appeals process follows that for direct taxes. Guidance on the appeals and review process for direct taxes is outlined in ARTG2010 and detail is at ARTG2100+.

A person who has received a notice of a penalty assessment under the Senior Accounting Officer (SAO) provisions may appeal against the assessment, see SAOG22200.

They must

  • appeal in writing to HMRC
  • appeal within 30 days of the date of the notice of the penalty assessment
  • state the grounds of their appeal, see SAOG22300.

The Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker must carefully consider the grounds of appeal and act upon the appeal in line with SAOG22400. It may be possible even at this stage to open or continue dialogue with a view to resolving the dispute.

Where the person is not satisfied with HMRC’s rejection of their appeal or the outcome of HMRC’s review of their decision (if they have asked for one) they may notify their appeal to an independent tribunal, the First-tier Tribunal, see SAOG22500.

Where there is an appeal against a penalty, payment of the penalty should be informally stood over pending resolution of the appeal, see SAOG22450.