ARTG15000 - Standard paragraphs for use in Appeals, Review and Tribunals correspondence
Source: gov.uk (2025-08-28)


This page contains a list of standard paragraphs and text that should be used when you are corresponding in appeals, reviews and tribunals cases. However, your business unit may have agreed different versions of these letters for specific types of case in your business area. Officers should check existing practice within their business area before using these standard templates.

Each link will take you to a Word version of the text relevant to the heading.

Decision Letters

The following letters should be used when issuing a letter containing an appealable decision.

Decision letter - Direct taxes

Decision letter - VAT and Excise

Decision letter - Customs

Decision letter - restoration decision

Explanation Letters

The following letters should be used to explain your intention to make an appealable decision. See ARTG2190 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg2190) for direct taxes, and ARTG3020 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg3020) for indirect taxes.

Explanation Letter - direct taxes

Explanation letter - indirect taxes

Late Appeal (direct tax)

If the customer has filed a late appeal to HMRC, follow the guidance in ARTG2240 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg2240). The following letter should be used to reject an appeal.

Late appeal to HMRC - refusal (direct)

Settlement of appeal by agreement (direct tax)

The following letter should be used to settle a direct tax appeal by agreement with the customer (see ARTG2720 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg2720)).

Settlement of appeal by agreement (direct)

Postponement (direct tax)

If the customer has asked for payment of tax to be postponed until their appeal is determined, see guidance in ARTG2510 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg2510). The following letters should be used to either agree or refuse postponement.

Determination of postponed amount

Disputed postponement

Review

These letters relate to the statutory review process.

For direct taxes, where the customer has appealed HMRC may offer a review in accordance with the guidance in ARTG4220 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg4220). The following letter should be used to provide HMRC’s View of the Matter and offer a review.

View of the matter letter with offer of a review - direct taxes

For direct taxes, if the customer has appealed and asked for a review, see the guidance in ARTG4290 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg4290). The following letter should be used to provide HMRC’s View of the Matter.

View of the matter letter without an offer of a review - direct taxes

For direct taxes, if the customer does not respond to an offer of review, see the guidance in ARTG2730 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg2730). The following letter should be used to inform the customer about a deemed settlement agreement.

Deemed Settlement under s54 TMA - direct taxes

For direct or indirect taxes, if the customer has accepted the offer of a review outside the time limit, see the guidance in ARTG4300 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg4300). The following letters should be used to refuse a late review request.

Late review acceptance refusal (direct)

Late review acceptance refusal (indirect)

Late review request refusal (restoration decisions)

Hardship (indirect tax)

The following letters should only be used by the Hardship Team in HMRC Legal Group and where the customer has appealed and made an application for hardship. See ARTG3330 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg3330) and ARTG3340 (https://www.gov.uk/hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg3340).

Hardship application - refusal insufficient information

Lesser security accepted

Security not required

Adequate security

Hardship application - acceptance by HMRC

Hardship application - acceptance by tribunal

Hardship application - refusal by HMRC