Beware the sting in the tail.
As readers will be aware as part of the changes that were introduced to the tax appeals process from 1 April 2009 an optional HMRC internal review procedure was introduced which provides a means of settling a dispute that has arisen between a taxpayer and HMRC without recourse to the tribunal (see TMA 1970 s 49A et seq and VATA 1994 s 83A et seq).
As the underlying principles are the same for both direct and indirect taxes (although there are differences in the way in which the actual operational review process is conducted) for ease of reference all statutory references below are to TMA 1970.
In...
