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HMRC internal manual

Tobacco: Anti-smuggling or the duty to avoid facilitating smuggling

Reviews and appeals: Which features of the regime are subject to appeal?



A tobacco manufacturer has the right to appeal a penalty notice to a departmental review and then if they wish to a tribunal. The matters for appeal are:


  • that the penalty notice should not have been issued
  • that the amount of the penalty has been incorrectly calculated.

A tobacco manufacturer may not formally appeal any other matter, however, they may make any representations on any issue to a review or appeal of the above 2 matters and the person reviewing the decision must take into account all relevant information.

A tobacco manufacturer must request a review within 30 days of the date of the penalty notice informing them of their rights for a review of our decision.

It is imperative that we ensure every decision we make is recorded and documented at every stage so that we are able to defend our actions where the need arises.