HMRC internal manual

VAT Civil Penalties

Breach of Walking Possession Order: Reconsiderations and appeals: Appeals and review process

A person has the right of appeal to the tribunal.

Reviewing the penalty

The issue of a penalty must be reviewed if a person

  • asks for an independent review, or
  • appeals to tribunal.

Guidance about reviews and appeals can be found in ARTG - Appeals reviews and tribunals guidance


The person should be notified in writing of the outcome of an independent review, please see ARTG3000 - Reviews and appeals for indirect tax for further guidance.

Appeal cases

All appeal cases should be reviewed in accordance with any specific instructions from the Solicitor’s Office and the guidance in ARTG. The reviewing officer should also consider if the person has a reasonable excuse, see VCP11532.