Where a taxpayer disputes an HMRC decision (except in relation to indirect taxes including VAT where no obligation to first appeal to HMRC exists), they must first make an appeal to HMRC and then, if the matter cannot be resolved, may notify the appeal directly to the First-tier Tribunal. This is covered in the commentary below.
For more details of the First-tier Tribunal, including the scope of its jurisdiction, see A5.605 and De Voil Indirect Tax Service V5.400F.
For details of the case management powers of the First-tier Tribunal, including its ability to strike out appeals and restrict a party from taking part in proceedings, see A5.606 and De Voil Indirect Tax Service V5.400J. For details of hearings in front of the First-tier Tribunal, see A5.609 and De Voil Indirect Tax Service V5.400J.
Appealing a decision by HMRC
Where a taxpayer disputes an HMRC decision in relation to direct taxes, they must first make an appeal to HMRC and then, if the matter cannot be resolved, may notify the appeal directly to the tribunal1.
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