Section 28 — review and appeal procedures

Find out about how you can request a review of a decision or submit an appeal.

28.1 If you disagree with any decision we make about your affairs 

When we make a decision that you can appeal against, we will tell you and offer you a review. We will explain the decision and tell you what you need to do if you disagree. 

For example with: 

  • the amount of an assessment 
  • the issue of a civil penalty 
  • a decision specifically connected to the relevant duty 

You’ll usually have 3 options. Within 30 days you can: 

  • send new information or arguments to the officer you’ve been dealing with 
  • have your case reviewed by a different officer 
  • have your case heard by an independent tribunal 

A review will be handled by a different officer from the one who made the decision. If you prefer to have an independent tribunal hear your case, you must write directly to the Tribunals Service. 

28.2 The time limit to ask for a review 

If you want us to review a decision, you must write to the person who issued the decision letter, within 30 days of the date of that letter. We will complete our review within 45 days, unless we agree another time with you. 

You cannot ask the tribunal to hear your case until the 45 days (or the time we agreed with you) has expired, or we’ve told you the outcome of the review. 

If you are not satisfied with the review’s conclusion, you have 30 days within which to ask the tribunal to hear your case. 

If we cannot complete our review within 45 days, or any time we agreed with you, we will ask you whether you’re willing to agree to an extension so that we can complete the review. If you do not agree to an extension, the review is treated as concluding that the decision being reviewed is upheld. 

We’ll write and tell you this, you then have 30 days from the date of that letter to ask the tribunal to hear your case. 

28.3 What you must include in your request for review 

Your request should set out clearly the full details of your case, the reasons why you disagree with us and provide any supporting documentation. You should also state what result you expect from our review. 

28.4 If you do not want a review 

If you do not want a review, you can appeal to the independent tribunal. You need to send your appeal to the Tribunals Service within 30 days of the date on the decision letter. 

28.5 Where you can get more information 

You can find more information about reviews and appeals in fact sheet HMRC1.