ECL33300 - Appeals and reviews: ECL liability during the appeal process

An appeal relating to an amount of levy due from a person cannot be considered by Tribunal unless the amount HMRC has considered to be due has been paid of deposited with HMRC.

The exception to this is when:

Either

• HMRC is satisfied that the requirement to pay or deposit the levy HMRC considers due would cause the appellant to suffer hardship,
• HMRC is not satisfied but the tribunal has decided that the requirement to pay or deposit the levy HMRC considers due would cause the appellant to suffer hardship,

And

• the appellant has paid or deposited such other amount (if any) by way of security as the HMRC Commissioners or the tribunal considers appropriate.