Jurisdiction(s):
United Kingdom

HMRC decisions and determinations checklist: appealability, reviews, strict time limits, judicial review, costs, FTT/UT procedure and payment issues (direct tax and VAT)

Published by a LexisNexis Tax expert

Checklists

FORTHCOMING CHANGE:

A consultation, which ended on 7 July 2025, invited feedback on ways to streamline, update and reshape HMRC’s approach to dispute resolution, with the goal of boosting awareness of the existing procedures and widening access to (and participation in) alternative dispute resolution (ADR) and statutory review routes. It further suggests adopting a clearer, harmonised appeals framework that draws together the strengths of the different models currently operating for both direct and indirect tax disputes. For additional detail, see the News Analysis pieces: Tax update spring 2025—Tax analysis—Taxes management and dispute resolution and Tax update spring 2025—Improving HMRC’s approach to dispute resolution.

This Checklist was prepared and authored by Anne Redston, Barrister. It represents her personal opinion; she is not authorised to speak for the Tribunals Service or the judiciary. Receipt of an HMRC decision usually triggers the timetable for an appeal to the First-tier Tax Tribunal (FTT). This Checklist may help you avoid overlooking vital points at that crucial juncture, when swift, informed action is required...

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Anne Redston

Anne Redston is consultant editor of Tolley’s Yellow Tax Handbook and a judge of the Upper Tribunal (Tax and Chancery Chamber) and of the First-tier Tribunal sitting in the Tax and Social Entitlement Chambers. Her contributions to TolleyGuidance and LexisPSL Tax are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Anne was until 2021 a tenant at Temple Tax Chambers from where she practised as a barrister, advising on a wide range of tax issues including employment and personal tax, VAT, social security and customs duties. As well as being a barrister, she is a Chartered Accountant and Chartered Tax Adviser, and a Fellow of both Institutes....

Web page updated on 20/05/2026

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