Updates: Appeals reviews and tribunals guidance
2025
First-tier and Upper Tribunals: Preparing for tribunal: Contents page
New Page ARTG8506- Applications for Anonymity
Additional sentence added to Anonymity order background paragraph
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Word templates moved to internal folder and links amended, updated versions of decision and 'view of the matter' letters, and amended SOLS to HMRC Legal Group following their renaming
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
Application to make an appeal is late added to first paragraph and last paragraph added
Addition of relevant legislation for other indirect taxes
Correction to when an extension of time to accept an offer of review can be made - appeal reference deleted
Additional information in relation to financial extremity for further appeals
Additional information in relation to financial extremity for further appeals
Additional information in relation to financial extremity
Review of direct and indirect taxes decisions: Introduction: Aims of the review
Last paragraph 'To take a fresh look at a decision' updated to include a link to ARTG4630
2024
Reviews and appeals overview: Process for indirect taxes
Introduction section updated. Information re extention of time period added
Review of direct and indirect taxes decisions: Arranging for a review: Triggers for a review
Link in bullet point 3 amended to ARTG4291
Reviews and appeals for direct taxes: Appealing against a decision: Invalid grounds of appeal
Wording change to Example 2
Reviews and appeals for direct taxes: Settlement of appeals: By agreement
Guidance amended throughout
Reviews and appeals for indirect taxes: Settlement of appeals: Settlement by agreement
Guidance amended throughout
Introduction: Complaints and appeals
Added link to complaints handling guidance at the end of the page
Judicial review: What is judicial review
3rd paragraph amended to add guidance for customer objection to HMRC's use of discretion
Reviews and appeals for direct taxes: Settlement of appeals: By agreement
Amended throughout
Last paragraph added with link to SAM11000
Last paragraph added with link to SAM11000
Last paragraph added with link to SAM11000.
First paragraph under subheading Indirect taxes amended
Reviews and appeals for direct taxes: Settlement of appeals: By agreement
Page amended throughout
Reviews and appeals for indirect taxes: Settlement of appeals: Settlement by agreement
Page amended throughout
Gifts: business assets: qualifying for relief
Page archived.
New second paragraph added
Third paragraph amended to include a link to page ARTG4290. And a new tenth paragraph added
Applications to the tribunal: Disputes about privileged communications
Last paragraph removed with stated there was no right to appeal. Previous paragraph amended to state there is a right of appeal against any penalty charged.
First-tier and Upper Tribunals: Preparing for tribunal: Role of the litigator
Officer titles and unit details updated
First-tier and Upper Tribunals: preparing for Tribunal: disclosure of information
Officer title and contacts updated
First-tier and Upper Tribunals: The tribunal hearing: Witnesses
Officer title
First-tier and Upper Tribunals: the tribunal hearing: disclosure of information
Contact information updated
First-tier and Upper Tribunals: The tribunal hearing: Security at the hearing
Contact details updated
Officer title and process updated
Contact details updated
'New information' paragraph amended to include arguments. New arguments paragraph updated and renamed to 'Considering new information or arguments'. Closing the case paragraph removed.
First-tier and Upper Tribunals: Introduction: Which tribunal considers the appeal
Office contact details updated
Officer title updated
Officer title and office updated
First-tier and Upper Tribunals: Appeals to the tribunal: Late appeals - application to the tribunal
Officer title and process updated
Officer title updated
First-tier and Upper Tribunals: Preparing for tribunal: Default Paper cases
Officer title and process updated
First-tier and Upper Tribunals: preparing for Tribunal: disclosure of information
Officer title and contacts updated
First - tier and Upper Tribunals: Preparing for Tribunal: Groups of related cases: Introduction
Officer title and updated
Officer title updated
Officer title updated
Officer title updated
Details in s83(1)(n) and (q) updated to reflect correct penalty provisions
Officer title details and procedure updated
Officer title details updated
Officer title details updated
Reviews and appeals for indirect taxes: Settlement of appeals: How appeals can be settled
Officer title updated
Reviews and appeals for indirect taxes: Settlement of appeals: Settlement by agreement
Officer title updated
Details of who to communicate with, Officer title and spelling updated
Review of direct and indirect taxes decisions: Arranging for a review: Who carries out reviews
Final paragraph amended
Review of direct and indirect taxes decisions: Arranging for a review: What are review teams
Content on what a review team is updated
Death and personal representatives: Bona vacantia and ultimus haeres
Page archived
Details of clearing house updated
Officer title update
First-tier and Upper Tribunals: Preparing for tribunal: HMRC not to defend case at tribunal
Second to last paragraph amended
Applications to the tribunal: without notice (ex-parte) applications
Contact details amended
Introduction: Litigation and Settlement Strategy
'Tribunals caseworkers' changed to 'litigators'
Introduction: Human Rights Act
'Tribunal caseworkers' changed to 'litigators'
Introduction: Guidance - indirect taxes
'Plastic packaging tax' added
Introduction: Complaints and appeals
'Tribunal caseworker' changed to 'litigator'
Officer title and unit contact details updated
Officer title details updated
First-tier and Upper Tribunals: Preparing for tribunal: Role of tribunals caseworker
Tribunal caseworker removed and replaced with litigator.
Applications to the tribunal: without notice (ex-parte) applications
Central policy (Tax Administration Advice) removed and replaced with Tax Administration and Legal Advice (TALA)
Applications to the tribunal: Tribunal consideration of applications
Tribunals caseworker removed and replaced with Solicitors office and Tribunals caseworker removed and replaced with Legal Services Litigator
First-tier and Upper Tribunals: Preparing for tribunal: Role of Solicitors office
Tribunal Caseworkers removed and replaced with Litigators
First-tier and Upper Tribunals: Preparing for tribunal: Preparation of the case
Tribunal caseworker removed from first paragraph and replaced with Litigator
First-tier and Upper Tribunals: Preparing for tribunal: Role of tribunals caseworker
Tribunal caseworker removed and replaced with litigator.
First-tier and Upper Tribunals: Preparing for tribunal: HMRC not to defend case at tribunal
Tribunals caseworker amended to Litigator and local compliance amended to solicitors office
Review of direct and indirect taxes decisions: Arranging for a review: Contents page
New page added 'Governance case boards and issue panels'
Reviews and appeals for direct taxes: Appealing against a decision: Time limits for making an appeal
Content changed re giving notice of appeal
Where notice of an appeal is received by HMRC after the time limit has expired, the customer can ask for their appeal to be accepted out of time see ARTG2240 added.
Guidance updated to add The decision maker should submit to the review team in SOLS within 7 calendar days using the Reviews and Litigation Submission Template.
Link to Reviews and Litigation Submission Template added
2023
Review of direct and indirect taxes decisions: arranging for a review: review arrangements
Link to the Reviews and Litigation Submission Template updated
Link to ARTG15000 fixed
Guidance amended throughout
Guidance amended throughout
Review of direct and indirect taxes decisions: arranging for a review: review arrangements
First and third paragraph amended
Guidance amended throughout
Link fixed
Fifth and sixth paragraphs amended
Guidance amended throughout
Guidance amended throughout
Guidance amended under subheading 'Non Customs cases'
Restoration decisions: Reviews and appeals: Customer asks for a review within the time limit
Guidance amended throughout
First-tier and Upper Tribunals: Preparing for tribunal: Role of tribunals caseworker
Second paragraph under the 'General' subheading amended
Restoration decisions: arranging for a review: late review requests
Amended throughout
Amended throughout
Amended throughout
Title amended and guidance amended throughout
Further amendment to the sixth paragraph
Minor reformatting
New third from bottom paragraph added
Reviews and appeals for direct taxes: Settlement of appeals: By agreement
Note amended
Reviews and appeals for direct taxes: Settlement of appeals: Where customer does not respond
New final paragraph added
Reviews and appeals for direct taxes: Appealing against a decision: Late appeals
New fifth paragraph added
New second paragraph added
Third paragraph amended. And new fourth paragraph added
Review of direct and indirect taxes decisions: Arranging for a review: Contents page
New page ARTG4291 added
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Amended throughout and two new letters - 'View of the matter letter with offer of a review - direct taxes' and 'View of the matter letter without an offer of a review - direct taxes'
Introduction: Litigation and Settlement Strategy
Guidance amended under the two subheadings
Instructions for where a customer appeals against a closure notice updated
Instructions for where a customer appeals against a closure notice updated
Second to last two paragraphs amended
Second to last two paragraphs amended
Resolution of appeal: payment of tax following an appeal
Page title and guidance amended throughout
Resolution of appeal: Repayment of tax overpaid
Guidance amended throughout
Resolution of appeal: Interest payable by HMRC on tax repaid
Page archived
Resolution of appeal: Interest payable by the customer on tax originally charged
Page archived
Resolution of appeals: Interest payable by the customer on additional tax due
Page archived
Resolution of appeals: contents
Pages ARTG11050, ARTG11060 and ARTG11070 archived
2022
Tenth paragraph amended
Fifth paragraph amended
Final paragraph under subheading Decision letters amended
Guidance amended throughout
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
Address amended
First paragraph amended
Guidance amended throughout
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Links placed after each standard paragraph
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Update to decision letters and review offer
Judicial review: What is judicial review
Link updated
Guidance amended under subheading 'Section 83(1)(e) The proportion of input tax allowable under section 26'
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
Third paragraph amended and new fourth paragraph added
Recent changes to this guidance
Page archived 鈥� Old legacy update page no longer required
Recent changes to this guidance
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: recent changes
Page archived 鈥� Old legacy update page no longer required
Page archived 鈥� Old legacy update page no longer required
Appeals, Reviews and Tribunals Guidance: Historic update index
Page archived 鈥� Old legacy update page no longer required
Guidance amended under subheading 'Section 83(1) (n) and (q) Liability to Penalties and Surcharge, and amount of Penalties, Surcharge and Interest'
New fifth paragraph added
New fifth paragraph added
2021
Guidance amended throughout
First-tier and Upper Tribunals: the tribunal hearing: disclosure of information
Guidance amended throughout
Guidance amended
Reviews and appeals for direct taxes: appealing to the tribunal: how a customer can notify an appeal
Guidance amended
Guidance amended
Guidance amended
Guidance amended
Guidance amended
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Paragraph regarding COVID 19 removed
Review of direct and indirect taxes decisions: Introduction: The review process
Final paragraph amended
Reviews and appeals overview: Process for direct taxes
Guidance amended under subheading 'Simple assessments'
Third paragraph amended
Review of direct and indirect taxes decisions: Introduction: Review process overview
Fourth paragraph amended
Review of direct and indirect taxes decisions: Introduction: Decisions that are not reviewable
Last bullet point amended
First-tier and Upper Tribunals: Preparing for tribunal: Strike out of a case
Guidance amended under subheading 'What happens if a case is struck out'
Bullet list under the first paragraph amended
Third paragraph under subheading 'Section 83(1)(p) and (r) VAT assessments under section 73 and 75 VAT Act' amended
Third paragraph under subheading 'Section 83(1)(b) The VAT chargeable on the supply of any goods or services' amended
2020
Guidance amended throughout
Resolution of appeal: Giving effect to the resolution of the appeal
Guidance amended under subheading 'Agreement without review or appeal to tribunal'
Judicial review: What is judicial review
Link in the final paragraph fixed
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
New paragraph added regarding COVID-19
First-tier and Upper Tribunals: preparing for tribunal: preparation of documents for the tribunal
Guidance amended to remove reference to the Service Level Agreement between HMRC and SOLS
2019
Review of direct and indirect taxes decisions: carrying out a review: during the review
Guidance amended throughout
Review of direct and indirect taxes decisions: introduction: role of the review officer
Guidance amended throughout
Applications to the tribunal: how to make an HMRC application
First address on page amended
Applications to the tribunal: how to make an HMRC application
Link to taxappeals@justice.gov.uk amended
First-tier and Upper Tribunals: Introduction: Matters that the tribunal may consider
Final paragraph amended
Fifth paragraph amended
Reviews and appeals for direct taxes: Settlement of appeals: Withdrawal of appeal
Second paragraph amended
Guidance amended under subheading 'Further appeal by HMRC'
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Removed links to Review conclusion letter (upheld), Review conclusion letter (varied), Review conclusion letter (cancelled), Review request acknowledgement, Deemed acceptance of review conclusion (direct) and Deemed review conclusion
Reviews and appeals overview: Process for direct taxes
First paragraph under the 'General' subheading amended
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
Third from last paragraph amended
2018
Page substantially amended
Guidance extensively amended
Guidance amended
Guidance amended
Applications to the tribunal: Joint applications to the tribunal
Amended due to partial closure notice legislation
Reviews and appeals for direct taxes: Appealing against a decision: Who can make an appeal
New paragraph added at the bottom of the page
New part 'Individuals subject to a Bankruptcy Order' added to the bottom of the page
Review of direct and indirect taxes decisions: Conclusion of the review: Introduction
The text in the three bullet points changed from 'original decision' to 'decision'
Introduction: Guidance - indirect taxes
'Soft Drinks Industry Levy' added to the page
Review of direct and indirect taxes decisions: Arranging for a review: Who carries out reviews
First paragraph amended to include a new first sentence. And second sentence amended
Review of direct and indirect taxes decisions: Arranging for a review: What are appeals units
First and third paragraphs amended
Review of direct and indirect taxes decisions: arranging for a review: review arrangements
First paragraph amended to include a new second sentence
Reviews and appeals for indirect taxes: Appealing against a decision or assessment: Contents page
New pages added - ARTG3041 and ARTG3042
Review of direct and indirect taxes decisions: arranging for a review: review arrangements
Guidance entirely re-written
2017
Amended due to partial closure notice legislation
Applications to the tribunal: Customer applications to the tribunal
Amended due to partial closure notice legislation
Reviews and appeals for direct taxes: Appealing against a decision: Time limits for making an appeal
The guidance under the 'Appeals sent to HMRC' part amended
The statement '30 days from the date HMRC decided not to carry out a review when the customer asked for a review outside the time limit and we refused, see ARTG4300' removed as no longer correct
New glossary item - Customer query of Simple Assessment
Introduction: reviews of HMRC decisions
New final paragraph reqarding Simple Assessment
Reviews and appeals overview: Process for direct taxes
Guidance amended under the 'Customer's rights' and 'Options following review' parts to include guidance on Simple Assessment
Guidance amended to include reference to 'simple assessment'
Reviews and appeals overview: Rights of appeal
New final paragraph regarding Simple Assessment
New second paragraph regarding Simple Assessment
New third paragraph regarding Simple Assessment
Review of direct and indirect taxes decisions: Introduction: The review process
New final paragraph regarding Simple Assessment
Review of direct and indirect taxes decisions: Introduction: Review process overview
New fourth paragraph regarding Simple Assessment
New second sentence added to first paragraph regarding simple assessments
Reviews and appeals for direct taxes: Payment of tax pending the outcome of an appeal: Contents page
New page added - Postponement of Simple Assessments
Review of direct and indirect taxes decisions: Introduction: Decisions that are not reviewable
New bullet point added - simple assessments
Applications to the tribunal: how to make an HMRC application
First address amended
Review of direct and indirect taxes decisions: Conclusion of the review: Action to take
Page amended to remove two paragraphs concerning amendments that would be needed to the customer's record to give effect to the review officer's decision
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
New address and third paragraph added
First-tier and Upper Tribunals: the tribunal hearing: conduct of the hearing
Link to CH265170 fixed
Fifth paragraph amended
Restoration decisions: Arranging for a review: HMRC decision upheld or varied
First paragraph amended to include the words 'Excise review team'
First-tier and Upper Tribunals: Introduction: Tribunals
Fourth paragraph, second sentence amended to include the words 'First-tier Tribunal'
First-tier and Upper Tribunals: Introduction: Which tribunal considers the appeal
First paragraph, second sentence under the 'Upper Tribunal' part amended to include the words 'First-tier Tribunal'
Third paragraph, second sentence amended to include the words 'First-tier Tribunal'
Appellate Court: Outcome of hearing by relevant appellate court
Second to last paragraph, third sentence amended to include the words 'Court of Justice of the European Union'
The text under the subheading 'Applications for costs by Solicitor鈥檚 Office following decision by Upper Tribunal or Appellate Court' has been entirely replaced
2016
New second paragraph added
Reviews and appeals for indirect taxes: Payment of tax pending the outcome: Hardship applications
First paragraph amended
Review of direct and indirect taxes decisions: Introduction: Aims of the review
Final paragraph removed
New second sentence added to the first paragraph
'Serious Organised Crime Agency (SOCA)' replaced by 'National Crime Agency (NCA)'
Final paragraph replaced with a new paragraph
Review of direct and indirect taxes decisions: Carrying out a review: Time limit for review
Second paragraph amended
Review of direct and indirect taxes decisions: Conclusion of the review: Action to take
Final two paragraphs replaced by a new paragraph
Second bullet point amended
Review of direct and indirect taxes decisions: Conclusion of the review: HMRC decision cancelled
Second paragraph amended
New paragraph and bullet points added at the end of the page
Restoration decisions: Reviews and appeals: Customer asks for a review within the time limit
Third paragraph amended
Restoration decisions: Arranging for a review: HMRC decision upheld or varied
First paragraph amended to include a new second sentence
Restoration decisions: Appealing against a review decision: Liaison with specialist offices
'Criminal Investigation' replaced by 'Fraud Investigation Service'
Applications to the tribunal: without notice (ex-parte) applications
Second bullet point in the fifth paragraph removed
Applications to the tribunal: how to make an HMRC application
Eighth paragraph amended. And first address amended, which now includes an email address and telephone number
Address amended to a new address
First-tier and Upper Tribunals: Introduction: Tribunals
Fourth paragraph amended to include an extra sentence
First-tier and Upper Tribunals: Introduction: Composition of tribunals
Second paragraph amended to include a new second sentence
First-tier and Upper Tribunals: Introduction: Which tribunal considers the appeal
First paragraph in the Upper Tribunal part amended to include a new second sentence
Third paragraph amended to include a new second sentence
Fourth paragraph amended
First-tier and Upper Tribunals: Preparing for tribunal: Withdrawal of case before the tribunal
Final paragraph amended
New second bullet point within the first paragraph
First-tier and Upper Tribunals: preparing for tribunal: preparation of documents for the tribunal
New final paragraph in the Who prepares the bundle? part
Final paragraph amended
First-tier and Upper Tribunals: The tribunal hearing: Evidence
New fourth paragraph added. And final paragraph amended
First bullet point in the Unreasonable or wasted costs part amended
New final paragraph added
Appellate Court: Outcome of hearing by relevant appellate court
Second to last paragraph amended and a new third sentence added
Resolution of appeal: What happens after tribunal appeal resolved
Title of the page amended. And third paragraph amended
Judicial review: Application to bring proceedings
Second and fourth paragraphs amended. And a new third paragraph added
Judicial review: Pre-action letters
Page substantially amended
Fifth paragraph amended
A new sixth paragraph added
Text and link to ARTG8060 removed
Introduction: Guidance - indirect taxes
'machine games duty' added to the list
Introduction: Complaints and appeals
Additional sentence added to the second paragraph
Reviews and appeals overview: Process for indirect taxes
New paragraph added to the Introduction part
Reviews and appeals overview: Introduction appeal to the tribunal
Link and text to ARTG8060 removed. And final two links amended to ARTG8990 and ARTG9000
Amendments made to the 'Appeal made by', 'Excise or Customs' and 'Landfill tax' parts
Additional sentences added to the first paragraph
Third paragraph amended
The 'Criminal investigations' part has been amended
First paragraph amended to include the word 'one' in the first sentence
First paragraph amended
First and sixth paragraphs amended
First paragraph amended
Standard paragraphs for use in Appeals, Review and Tribunals correspondence
'Decision Letter - direct taxes' template removed. And 'Review offer - direct taxes' template amended
Reviews and appeals for direct taxes: Appealing against a decision: Time limits for making an appeal
First paragraph amended
Reviews and appeals for direct taxes: Appealing against a decision: Time limits for making an appeal
First paragraph amended under the 'Appeals sent to HMRC' part of the page
Final paragraph under Direct taxes has been amended
First-tier and Upper Tribunals: Outcome of the tribunal proceedings: Tribunal decisions
A Note added near the end of the First-tier Tribunal part of the page
First bullet point amended to include instructions on how to stand over a penalty