ARTG4290 | Review of direct and indirect taxes decisions: Arranging for a review: Asking HMRC for a review (direct taxes)

Direct taxes

If the decision maker has not offered a review, the customer may ask for a review at any time after making their appeal unless they have already notified the appeal to the tribunal.

They can ask for a review by writing to the decision maker, who should then reply to the customer

• within 30 days of their request for a review

• setting out HMRC’s current view of the decision, see ARTG2213, and

• arrange for a review to be carried out, see ARTG4330.

The view of the matter letter must always be sent directly to the customer, even if we routinely deal with the agent. Where a customer has an agent acting, a copy of the letter offering a review may also be sent to the agent.

Standard template wording for giving HMRC’s view of the matter can be found in ARTG15000.

If, exceptionally, the decision maker cannot reply to the customer within 30 days of his request (perhaps because they also sent in substantial new information) they should acknowledge the customer’s request and reply in full as soon as possible, but within a reasonable longer period, keeping the customer informed of any delay.

If the customer has not already appealed but asks for a review, the decision maker may accept the review request as also being an appeal to HMRC, provided it meets the relevant criteria.

They must contact the customer straightaway if further information is necessary for a valid appeal, see ARTG2140. The time-limited period within which to send our view of the matter will have begun when the appeal or a review request that we accepted as a valid appeal was received by HMRC, see ARTG2213.