Reviews reviewed

We have had two good experiences of the internal review process recently (in relation to VAT cases).

HMRC were alleging that two sporting clubs didn’t qualify for the non-profit making exemption. They issued decisions to this effect (supported by a detailed – circa six pages – letter setting out their reasons).

It appeared that they had taken a policy decision that this was a point of principle and we therefore anticipated having to go to the tribunal. We applied for a review (supported by a 27-page submission) more in hope than expectation. We thought we had a very good case but we didn’t expect the review process to be anything more than a procedural obstacle.

We were therefore delighted that the reviewer agreed entirely with us and withdrew HMRC’s decisions immediately. The whole review process was undertaken timeously and was well conducted.

The initial review decision didn’t contain...