There are over 12,000 taxpayer disputes with HMRC each tax year. The issue of a tax assessment, a penalty decision, or differences over the conclusion of an investigation are a few of the reasons why taxpayers found themselves in a dispute with HMRC. 

It is usually possible to appeal an HMRC decision, but taxpayers must follow prescribed steps and meet strict time limits. Expert guidance is essential to determine the best way forward.

HMRC dispute resolution: your options

  • HMRC appeals
  • Independent internal review
  • Alternative dispute resolution
  • Tax Tribunal support

HMRC appeals

If you disagree with an HMRC decision, an appeal must be submitted inside the statutory time limit, usually within 30 days from the decision date. You will need to include a valid reason for disagreeing with HMRC’s decision.  

Late appeals are permissible, but you will be required to demonstrate a reasonable excuse for failing to submit the appeal on time.

Our team can support you with the appeal process and deadlines. 


Independent internal review

An independent internal review is often the first step in the dispute process after submitting an appeal. It involves a review of the case by an independent HMRC officer. The review determines whether HMRC’s decision was made in line with the legislation and HMRC guidance.

HMRC must respond to a request for an independent internal review within strict time limits. This can be an efficient way of reaching a resolution.


Alternative dispute resolution

Alternative Dispute Resolution (ADR) can be a favourable alternative for both HMRC and the taxpayer to reach or negotiate a resolution, especially in long-running cases. 

You may wish to consider ADR instead of the Tax Tribunal if you have been unable to settle your HMRC dispute through negotiation.

There are several advantages of ADR - it can be time-efficient and less costly, it maintains confidentiality and it allows the taxpayer and their adviser to retain some control. 

While there are rules to follow, an application for ADR can be used in conjunction with an appeal to the Tribunal, so advice should be sought before an application is made.


Tax Tribunal support

Not all HMRC disputes can be resolved through the independent internal review or ADR. In some cases, it may be necessary to take an appeal to the First-tier Tax Tribunal, which is independent of HMRC.

An appeal to the Tribunal can be a long and expensive process, with no guarantee of success. It is especially important to take advice and to carefully consider the advantages and disadvantages before proceeding.


How we can help resolve HMRC disputes

If you are in a dispute with HMRC or need to appeal a decision, our team of tax dispute resolution experts is here to help.

Within our team, we have chartered tax advisers and fully qualified HM Inspectors of Taxes, who have significant experience in dealing with HMRC disputes. 

We can help you understand your position and the best way to deal with any issues. We will also guide you through the entire process, including acting on your behalf during negotiations.

To speak with us in confidence about your situation and how our specialist team can help you, please call us on +44 (0)800 032 8374