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 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. See V5.400N and Simon's Taxes A5.613.
The commentary below covers hearings in front of the Upper Tribunal.
Preparing skeleton arguments and bundles
Both parties must prepare skeleton arguments outlining their case which must be filed with the Upper Tribunal in advance. The Upper Tribunal will issue directions stating the date by which the skeleton arguments must be submitted1.
When preparing skeleton arguments for the Upper Tribunal, it is important to follow the requirements set out in the Guidance on the conduct of
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