Appealing an HMRC decision ― outline

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Personal Tax

Guidance

Anne is a barrister who sits as a judge of the Upper Tribunal (Tax and Chancery Chamber) and the First-tier Tax Tribunal. The commentary in this guidance note is her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary.

Introduction

This note outlines the procedure for appealing against a decision made by HMRC. It links to further notes which explain each stage of the procedure. See also the Flowchart ― appeal process at a glance ― direct taxes and Flowchart ― appeal process at a glance ― VAT which visually summarise the process.

Note that the Government has proposed an alignment of the processes for appealing a direct taxes and VAT decisions. For more details, see the Tax Administration Framework Review: Improving HMRC’s approach to dispute resolution (Apr 2025).

This guidance note and the further notes on appealing to the Tribunal are only a summary; they do not cover all situations. You may need to take further advice in relation to the taxpayer’s

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Anne Redston

Barrister

Anne Redston is a barrister and consultant editor of Tolley's Yellow Tax Handbook. She is also a judge of the Upper Tribunal (Tax and Chancery Chamber), the First-tier Tax Tribunal and the Social Entitlement Tribunal. She is a Chartered Accountant and Chartered Tax Adviser, and a Fellow of both Institutes.

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