Disputes with HMRC: appeals

FORTHCOMING CHANGE: The Tribunal Procedure Committee (TPC) consultation on the provision of written reasons for decisions (30 July to 22 October 2024) includes proposals to amend the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, SI 2009/273. For more information, see LNB News 13/08/2024 4.

Most HMRC decisions are able to be appealed by the taxpayer.

Once a taxpayer has received an appealable decision, the clock has already started to run for:

•
requesting an HMRC review of that decision, and
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appealing it to the First-tier Tax Tribunal (FTT)

Below is an overview of the appeals procedure and the matters to be considered by a taxpayer:

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before launching an appeal, and
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throughout the appeal process

The procedure differs if the matter in dispute is a direct tax or a VAT matter.

See also: Practical steps following a decision in tax matters—checklist.

This subtopic concerns disputes with HMRC. For disputes with Revenue Scotland, see: Disputes with Revenue Scotland: appeals—overview.

For an illustration of how, in relation to appealable decisions made by HMRC (ie those HMRC decisions

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