Additional only for direct taxes
In both cases HMRC has 45 days within which to complete the review (unless the customer agrees another period).
After the review conclusion is notified, the customer will have 30 days to appeal to the tribunal. If they do not appeal to the tribunal, the review conclusions (which may be that our decision is upheld, varied, or cancelled) will become final.
Late review acceptances and late appeals to HMRC should be allowed where there is a reasonable excuse. There will be no change to existing rights for customers to postpone payment of tax until their appeal is settled. Although the process has been changed so that if we do not agree with an application, we must notify the customer and it is for them to send it to the tribunal if they wish to take it further. Any postponement should be maintained throughout the review process until the matter is settled.
A special transitional process will apply for appeals that are ready for hearing before 1 April and which cannot be listed for the last General Commissioners' meeting. Until 1 April, HMRC will be able to arrange for these to be heard by the new tribunal.