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HMRC internal manual

VAT Assessments and Error Correction

VAT assessments: types of assessment: protective assessments: appeals

A person may appeal against a protective assessment in the normal way. There is no requirement to pay the assessment in order to appeal.

You should advise the appellant to inform the tribunal that we have agreed to request payment only if HMRC’s appeal is upheld.

There is further guidance on appeals in ARTG3000.