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HMRC internal manual

Senior Accounting Officer Guidance

Appeals: Notifying a person that their appeal is rejected

If following consideration by the Penalties Consistency Panel and, where appropriate the Director in Large Business or Assistant Director in Mid-sized Business, an appeal is rejected, the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker must notify the decision to the appellant.

The CCM, CET or Caseworker must set out HMRC’s position in a ‘view of the matter’ letter to the person, the company or the Senior Accounting Officer (SAO). This letter will set out the person’s options to

  • take no action (or accept HMRC’s position)
  • accept the offer of a review, see ARTG4220 and ARTG15000 – Decision Letter – direct taxes, or
  • notify the appeal to the tribunal.