KEY POINTS
- An optional internal review can avoid litigation.
- Insufficient explanation given by the reviewing officer.
- How independent is the decision?
- HMRC officers should be better informed.
It is nearly two years since HMRC introduced their optional internal review process. Taxpayers can use the process to have disputed tax decisions considered by an HMRC officer who is independent of the original decision maker.
The idea is to resolve the case without going to a tribunal. While the process has plenty of merit for example avoiding a tribunal hearing saves time money and stress it is still an HMRC officer reviewing the case so any idea that the process is truly independent is inevitably going to meet with some scepticism.
Figures for the first 12 months of the review process i.e. 2009/10 were...
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