What is the difference between a self-assessment appeal and a review?

Here are the key differences between an appeal and a review:

Appeal

What it is:

• Your initial challenge to an HMRC decision or charge
• A statutory right to dispute HMRC’s action
• The first step in the dispute process

Who handles it:

• Decision Maker (Appeals Handler or Review Interest Officer)
• Usually the same office that would normally handle your case
• Officer who made the original decision (in some cases)

Process:

• Must be made within 30 days of Notice of Liability
• Written (though some telephone/online appeals accepted)
• HMRC reviews the facts and makes a decision
• Charge typically stood over during consideration

Review

What it is:

• A second look by HMRC when they disagree with your appeal
• An internal HMRC process with a different officer
• Alternative to going straight to Tax Tribunal

Who handles it:

• Different HMRC officer who wasn’t involved in the original decision
• Often specialist review units (e.g., Appeal Review Unit in Nottingham)
• Independent internal review of the case

When it happens:

• After HMRC refuses your initial appeal
• HMRC offers you a review instead of immediate tribunal referral
• You can request a review if not offered
• You can decline and go straight to tribunal

The Sequence

1. HMRC Decision/Charge
         ↓
2. Your Appeal (within 30 days)
         ↓
3a. HMRC agrees → Appeal allowed
         OR
3b. HMRC disagrees → Review offered
         ↓
4. Review by different HMRC officer
         ↓
5a. Review upholds your position
         OR
5b. Review maintains HMRC position → Tax Tribunal option

Important Notes:

• You don’t have to accept a review – you can go straight to Tax Tribunal
• Review is free and often faster than tribunal
• Different perspective – fresh eyes on your case
• No time limit for HMRC to complete review (though they aim for reasonable timeframes)
• Tribunal remains available if review doesn’t resolve the matter

The review system was introduced to provide an independent internal challenge to HMRC decisions before the formal tribunal process, potentially saving time and costs for both parties.