Most HMRC compliance checks conclude without significant disagreement. However, where a taxpayer or business disagrees with an HMRC decision, there are established review, appeal and dispute-resolution procedures available.
This page provides educational guidance on the main routes available to taxpayers and businesses, including statutory review procedures, appeals and Alternative Dispute Resolution (ADR). The aim is to help businesses understand the available options and resolve disputes constructively and proportionately.
Key Points
• Understand the decision being challenged.
• Check any review or appeal deadlines carefully.
• Gather evidence supporting the business position.
• Consider whether ADR may assist in resolving the dispute.
• Maintain professional communication throughout the process.
• Follow the appropriate statutory procedures.
Internal reviews
Appeals to the tribunal
Alternative Dispute Resolution (ADR)
Deadlines and procedures
Evidence and supporting documents
Resolving disagreements constructively
Internal Reviews
An internal review allows a taxpayer to ask HMRC to reconsider a decision before progressing to a formal appeal. Reviews are normally carried out by an HMRC officer who was not directly involved in the original decision, providing an opportunity for the matter to be reassessed independently within HMRC.
Appeals to the Tribunal
Where a dispute cannot be resolved through correspondence or an internal review, a taxpayer may be entitled to appeal to the First-tier Tribunal (Tax Chamber). The tribunal is independent of HMRC and considers evidence from both parties before reaching a decision based on the facts and relevant legislation.
Alternative Dispute Resolution (ADR)
Alternative Dispute Resolution is a voluntary process that uses mediation to help taxpayers and HMRC resolve disputes without formal tribunal proceedings. ADR can help clarify misunderstandings, identify areas of agreement and encourage constructive discussions aimed at resolving outstanding issues.
Deadlines and Procedures
Review and appeal rights are subject to statutory deadlines and procedural requirements. It is important to understand the relevant timescales, submission requirements and available options to ensure that rights are protected and opportunities to challenge decisions are not missed.
Evidence and Supporting Documents
Supporting evidence often plays a significant role when challenging an HMRC decision. Businesses and taxpayers should retain records, correspondence, calculations and other documents that help explain their position and support any review, appeal or dispute resolution process.
Resolving Disagreements Constructively
Many disputes can be resolved through open communication, clear explanations and the provision of relevant evidence. A constructive approach can help narrow areas of disagreement, improve understanding and potentially avoid the need for lengthy formal proceedings.
Last Reviewed: June 2026