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ECL33300 | Appeals and reviews: ECL liability during the appeal process

From HM Revenue & Customs · Economic Crime Levy

An appeal relating to an amount of levy due from a person cannot be considered by Tribunal unless the amount HMRC has considered to be due has been paid of deposited with HMRC.

The exception to this is when:

Either

  • HMRC is satisfied that the requirement to pay or deposit the levy HMRC considers due would cause the appellant to suffer hardship,

  • HMRC is not satisfied but the tribunal has decided that the requirement to pay or deposit the levy HMRC considers due would cause the appellant to suffer hardship,

And

  • the appellant has paid or deposited such other amount (if any) by way of security as the HMRC Commissioners or the tribunal considers appropriate.