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 the actions that follow the issue of an Upper Tribunal decision.
For details of the hearing of cases by the Upper Tribunal, see V5.400P and Simon's Taxes A5.615.
Matters that might arise following the issue of the decision
There are various actions that might be necessary once the decision of the Upper Tribunal has been issued:
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