ARTG2050 | Reviews and appeals overview: Introduction appeal to the tribunal
From HM Revenue & Customs · Appeals reviews and tribunals guidance
In most cases where a customer’s appeal is considered by the tribunal, it will be considered by the First-tier Tribunal, see ARTG8000.
If either the customer or HMRC are dissatisfied with the decision of the First-tier Tribunal, they may be able to appeal to the Upper Tribunal
The Upper Tribunal may also, in special circumstances, with the agreement of the parties and the consent of the tribunal, hear cases in the first instance, without the case being heard by the First-tier Tribunal.
These appeals are likely to be those where there are substantial and complex points of law and limited facts to be found.