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HMRC internal manual

VAT Assessments and Error Correction

Protective assessments: Appeals

Under sections 84(3) and (3A) Vat Act 1994, the Tribunal is unable to hear an appeal against an assessment unless

  • the amount of the assessment ‘has been paid or deposited’ to HMRC, or
  • the amount has not been paid or deposited because


  • HMRC agree that the business would suffer hardship, or
  • The tribunal agree that the business would suffer hardship.

If a business decides to appeal against a protective assessment, you should advise it to inform the Tribunal that we have agreed only to request payment if HMRC’s appeal is upheld.

The business may wish to attach a copy of the letter of assessment to the Tribunal with the application form TS-TaxAp1.