ARTG3050 - Reviews and appeals for indirect taxes: appealing against a decision or assessment: telling the customer of the decision
Source: gov.uk (2025-07-22)


In many cases we will tell the customer of our decision by sending them a computer generated notice, such as an assessment.

If we do not send a computer generated notice we must tell the customer of our decision by sending them a decision letter.

The customer's right of appeal is against the decision contained in the notice of decision, that is, the notice of assessment (including accompanying notes), or decision letter as appropriate.

If we send the customer a computer generated notice, it is good practice to also send them a letter of explanation, see 'Explanation letters' below.

Decisions letters

The decision letter should usually
- explain to the customer
- what we believe the facts to be
- what our decision is
- the reasons for our decision
- the law supporting our decision
- what will happen if we do not hear from the customer within the time limit
- tell the customer of their rights if they disagree, including
- what to do if they have new information
- our offer of a review of the decision (where the decision is reviewable)
- their right of appeal (where it is an appealable matter)
- the relevant time limits, see ARTG3120 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg3120), and
- where to get further information
The decision maker must include an offer of an HMRC review of the decision in their decision letter, see ARTG4230 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg4230), when telling the customer of an appealable decision, see ARTG3040 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg3040).

The decision letter should state clearly that the customer should write directly to HMRC Legal Group if they wish to accept the review offer, using the relevant standard template wording in ARTG15000 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg15000).

Explanation letters

In an explanation letter we should usually explain to the customer
- what we believe the facts to be
- what our decision is
- the reasons for our decision
- the law supporting our decision
- the tax we believe to be due, if appropriate
- what will happen if we do not hear from the customer within the time limit.
This information will help make sure that the customer and their agents understand the decision we have made, the reasons and the legal basis. The decision maker should bear in mind, particularly where the customer is unrepresented that their letter should be clear and easy to understand even if referring to legislation.

If the customer subsequently accepts our offer of a review of the decision, see ARTG4000 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg4000) onwards, the review officer should easily be able to identify from the explanation letter
- the decision they are required to review
- the facts on which the decision maker relied
- the decision maker's reasoning, and
- the relevant legislation.
Where the decision maker is notifying the customer of a decision following a penalty warning letter, see EM5207b (https://www.gov.uk/hmrc-internal-manuals/enquiry-manual/em5207b).

Accountancy issues

Where a Decision Notice relies on accountancy, the accountancy position must be agreed in accordance with the Commissioners’ Advisory Accountant’s procedures, which means you must refer it to an accountant as soon as possible: the Advisory & Forensic Accountants SharePoint page has a link to ‘Find an Accountant’ to obtain the contact details of an accountant for your business area.