If you cannot agree with the officer, you can ask for a review by a different HMRC officer. That review rarely reverses the whole case, but it sometimes does. After that, the Tax Tribunal — part of the court system — decides.
Most appeals start in the First-tier Tribunal. Appeals from there are usually on law, not facts, to the Upper Tribunal, and in some cases onwards to the Court of Appeal or the Supreme Court.
What a First-tier hearing is like
It is the least formal of the tax courts, and still formal enough to unsettle most people. A judge, sometimes with a colleague, hears both sides. Witnesses can be called and questioned. The decision may be given on the day or later in writing. A short reasoned decision can be followed by a longer one if requested.
The whole case has to be put first time. New arguments are hard to introduce later. Legislation and earlier cases that help you should be in the bundle; so should the ones HMRC will use, with your answer already written.
How Solaratax helps
We give you a frank view of prospects. Often a fresh adviser can unblock a stuck negotiation, which is cheaper than a hearing. If we go to the tribunal we prepare the evidence and present it. Most of our investigation files still finish by agreement.
Call 01615 314179 or email enquiries@solaratax.co.uk for a free, confidential discussion. We will not contact HMRC in your name until you instruct us to act.
Questions we are asked
Related investigations
Tax litigation advice
When two parties are already in a legal dispute and tax sits in the middle — and your usual adviser cannot be independent.
Code of Practice 8 — tax avoidance investigations
Serious suspected loss of tax without an allegation of fraud — usually a planning structure or marketed scheme.
HMRC tax investigations
What an HMRC enquiry actually is, how it can escalate, and how we keep the case in the civil system wherever we can.
Talk to Solaratax
128 City Road, London, EC1V 2NX. 01615 314179. enquiries@solaratax.co.uk. Free, confidential, no obligation.
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