HMRC statutory reviews

Jan 11, 2021

HMRC has issued this reminder about statutory reviews.

“Customers are entitled, by law, to a statutory review if they disagree with an appealable HMRC decision. The review is conducted by officers who are entirely outside the management chain of those making the disputed decisions.

The reviews process is rigorous; most conclusions are counter-signed by an officer of a senior grade to the review officer. They are also a quick, easy and cost-effective way to settle a dispute and following a review, the majority of cases do not proceed to Tribunal.

Appealing direct to Tribunal can be costly and the reviews process allows customers to avoid unnecessary litigation, cost and stress, but they can still appeal to Tribunal if they disagree with a review conclusion.

The purpose of the review is to take a fresh look at the decision, not to assess new facts or evidence.  However, the review officer will give the customer the opportunity to send in further information during the review period.

Some disputes involving a direct challenge on HMRC’s interpretation of legislation may need to be determined by the courts, since a review officer cannot override HMRC policy. However, even in these cases a review can often help clarify facts and both party’s understanding of the dispute.

More information can be found in the appeals reviews and tribunal guidance manual.”