Disagree with a tax decision or penalty
Get a review
You can get a tax decision or penalty looked at by someone in a different team who was not involved in the original decision (a ‘review officer’). This is known as a ‘statutory review’.
For direct tax decisions and penalties, you must appeal to HM Revenue & Customs (HMRC) first before you can get a review.
For indirect tax decisions and penalties, HMRC will offer you a review at the time they send you their decision or penalty.
How long a review takes
Reviews usually take 45 days – the review officer will contact you if it will take longer.
What to include
When you ask for or accept the offer a review, it helps to tell HMRC:
- your name
- your reference number, for example your VAT registration number (VRN)
- why you disagree
After the review is complete
When the review officer has completed the review they’ll write to you to either:
- uphold the decision (the original decision is unchanged)
- vary the decision (the original decision has changed)
- cancel the decision
If the review officer upholds or varies the decision and you agree with the outcome, you’ll need to pay whatever you owe.
If HMRC cancels their decision after the review, you do not need to do anything.
If you disagree with the result of the review, you can appeal to the tax tribunal. You must usually do this within 30 days of the date on the review result letter.
You can also consider alternative dispute resolution (ADR), but you need to appeal to the tax tribunal first.