Where a customer has appealed to the tribunal against an HMRC
decision and the tax was not paid because the customer was granted
hardship or a certificate for security, once the tribunal has
decided the matter the customer must pay any tax due.
If the tribunal finds in the customer’s favour HMRC
must repay any overpaid tax. But see
ARTG8930 where there is an appeal to the
Upper Tribunal or the relevant appellate court.
