Where a taxpayer disputes an HMRC decision, they must first make an appeal to HMRC (except in relation to indirect taxes including VAT where no obligation to first appeal to HMRC exists) and then, if the matter cannot be resolved, may notify the appeal directly to the First-tier Tribunal. See A5.605–A5.610 and De Voil Indirect Tax Service V5.400F–V5.400K for details of appeals to the First-tier Tribunal.
Once the First-tier Tribunal has issued a decision with full reasons, either party (or both) may wish to appeal the decision to the Upper Tribunal.
An appeal cannot be made to the Upper Tribunal until the party has been given permission by either the First-tier Tribunal or the Upper Tribunal. This is discussed in the commentary below along with details of matters that are referred up to the Upper Tribunal by the First-tier Tribunal.
For details of hearings in front of the Upper Tribunal, see A5.615 and De Voil Indirect Tax Service V5.400P.
Application for permission to appeal to the Upper Tribunal
Appeals from the First-tier Tribunal can be made
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Web page updated on 17 Mar 2025 17:21