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Asking to have an HMRC decision reviewed

Asking to have an HMRC decision reviewed

Hi all

If you are dealing with an Inspector who is being "unreasonable", is it a good choice to try and have his decision reviewed or is it better to go straight to the Appeal Tribunal?

What are the pros and cons? 

Thanks a lot


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30th Jan 2013 17:28


I would generally ask HMRC to undertake an Internal Review. Although I find they usually support the original decision, such a Review is required to provide clear reasons for the decision. The review should, therefore, provide an indication of the argument to be taken should the matter proceed to Appeal.

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30th Jan 2013 18:19

Always ask for a review

With the last 2 that I did,

One decision was overturned

The other resulted in reduction of penalty from over £20k to under £2k.

At no cost to the client other than passing info to the Review Officer.

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31st Jan 2013 08:36

I would agree with Les that you should always request an Internal review as some decisions do get overturned and also you should explore all avenues open to you as it can uncover facts which either you or the asessing officer were unaware of. Additionally if it does go to appeal it demonstrates that you have sought to resolve the matter in the correct manner.

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31st Jan 2013 16:04

All agree with a review

Taking a case to Tribunal can be costly and it can often take up to a year before the case is heard in the Tribunal depending upon the complexity of the appeal.  Costs can no longer be recovered from the Tribunal unless you can show that HMRC have acted unreasonably.

Worth considering making a formal complaint against the unreasonable inspector as you may be able to recover costs for the client if your complaint is upheld.

Malcolm McFarlin


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By plato
22nd Apr 2013 20:09

Thanks a lot to all

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