Additional only for indirect taxes

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Additional only for indirect taxes

As now, the requirement to pay any disputed tax will be suspended during review (except in customs cases). If the conclusion of the review is that tax is due, this must be paid before an appeal can be heard. However, if payment would cause the customer hardship, they may ask HMRC to agree to suspend the tax until the tribunal appeal is settled. If HMRC does not agree, the customer can ask the tribunal to decide the matter.

In Customs and Excise duties and the environmental taxes, the current mandatory review will become optional, so that customers will be offered a review when an appealable decision is made. They can then decide whether or not to accept the decision, accept the offer of review, or appeal to the tribunal. However the existing mandatory review process will continue for decisions about the restoration of seized goods.

Review is not the same as local reconsideration. Review is a statutory process with strict time limits. Queries about decisions, especially in cases where the taxpayer provides new information, are not to be treated as review requests unless the customer has specifically asked for a review. In many such cases we expect to be able to reach agreement and finalise cases without a review as now.