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HMRC internal manual

Senior Accounting Officer Guidance

Appeals: A person's response to options set out in HMRC's view of the matter letter

If a person, the company or Senior Accounting Officer (SAO) notifies their agreement with HMRC’s current view or does not respond to a ‘view of the matter’ letter their appeal will be treated as settled by agreement 30 days from the date of the ‘view’ letter, see ARTG2700. If the penalty has previously been stood over the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker should instruct the SAFE nominee to reinstate it.

The person must accept a review offer within 30 days of the ‘view of the matter’ letter.

If they opt for a review they can still go to the tribunal if they are not satisfied with the outcome of the review, see SAOG22440.

A review requested by the appellant will lead to the cancellation of the penalty if the review decision is in the appellant’s favour.

Guidance on appeals to the tribunal is found at SAOG22500, ARTG2010 and ARTG2400. A person cannot appeal to the tribunal while a review is being carried out, see ARTG4640.