HMRC internal manual

Senior Accounting Officer Guidance

SAOG22300 - Appeals: how to appeal or make late appeal

The appeal must be given in writing to HMRC.

It must state the grounds of appeal.

An appeal must be made within 30 days of the date on the notice of the penalty assessment.

Late appeals

The person to whom the penalty is charged, or their authorised agent, may make a late appeal, see ARTG2240. The Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker must accept a late appeal if the person had a reasonable excuse for not appealing within the time limit and the person appealed without unreasonable delay after the excuse ended.

If the conditions for a late appeal are not met the CCM, CET or Caseworker must inform the company or Senior Accounting Officer (SAO) accordingly. The CCM, CET or Caseworker must also

  • explain that if they wish to pursue their appeal, they should apply to the tribunal for permission for a late appeal and
  • provide details of how to apply to the tribunal, see ARTG8240.