Jurisdiction(s):
United Kingdom

Key definition

Allocation definition

What does Allocation mean? In civil litigation, allocation is the court’s decision, by order, placing a defended claim on the appropriate case management route. In England and Wales, it is governed by the Civil Procedure Rules (CPR) Part 26. Using information in the parties’ Directions Questionnaires (formerly allocation questionnaires) and any statements of value, the court typically allocates on the papers to one of four tracks: small claims, fast track, intermediate track, or multi-track. It considers factors such as monetary value, complexity, importance, remedies sought, number of parties, need for experts and expected trial length. The allocation order may include initial...

HMRC appeals in the First-tier Tribunal (Tax Chamber): from notice of appeal to hearing—forms, categorisation, directions, witnesses, overseas evidence, bundles, skeletons and AI risks

Published by a LexisNexis Tax expert

Practice notes

Practice Note

This Practice Note has been prepared by Anne Redston, Barrister, and reflects her own perspective; she is not authorised to speak for the Tribunals Service or the judiciary in any capacity. The Note explains what to do once a taxpayer chooses to appeal an HMRC decision to the First-tier Tax Tribunal (FTT). It spans the period from the outset of the appeal process through to the hearing date, and carefully considers, among other relevant procedural matters:

the appeal form—where to find it and practical guidance on completing it correctly
the FTT’s Allocation of the case to a category and the effects and implications of that allocation
pre-hearing directions issued by the FTT
handling evidence expected to be given by video or telephone from a location outside the UK, and
matters relating to preparing:
- witness statements
- trial bundles
- skeleton arguments, and
the use of artificial intelligence (AI) in tax litigation

For the next stage, see Practice Note: What happens at a tax tribunal hearing? Before reading this Practice Note, it is important also to read the Practice Notes: Appealing an HMRC decision and Should I appeal to the tax tribunal?...

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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 21/05/2026

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