Adam Craggs and Jonathan Levy provide a refresher guide to the rules on HMRC’s internal review process
In direct tax cases it is necessary for a taxpayer who disputes a decision to firstly make an appeal to HMRC rather than to the tribunal. The direct tax legislation therefore talks in terms of the taxpayer ‘notifying an appeal’ to the tribunal if he wishes once he has made the initial appeal to HMRC to pursue his appeal before the tribunal.
Taxpayers should be careful to appeal to HMRC within the stipulated time limits which depend on the statutory provisions in question but are usually within 30 days (see for example TMA...
