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Where a taxpayer disputes an HMRC decision, they must first make an appeal to HMRC (except in relation to indirect taxes including VAT where no obligation to first appeal to HMRC exists) and then, if the matter cannot be resolved, may notify the appeal directly to the First-tier Tribunal. See V5.400F–V5.400K and Simon's Taxes A5.605–A5.610 and for details of appeals to the First-tier Tribunal.

Once the First-tier Tribunal has issued a decision with full reasons, either party (or both) may wish to appeal the decision to the Upper Tribunal.

However, an appeal cannot be made to the Upper Tribunal until the party has been given permission by either the First-tier Tribunal (see V5.400K and Simon's Taxes A5.610) or the Upper Tribunal (see V5.400N and Simon's Taxes A5.613).

The commentary below discusses the case management powers of the Upper Tribunal, including its ability to strike out appeals and restrict a party from taking part in proceedings. For details of hearings in front of the Upper Tribunal, see V5.400P and Simon's Taxes A5.615.