2.4.1 Right to appeal late

The discussion in 2.3.1 above makes clear that taxpayers should generally do the following within 30 days:

give a written appeal against the decision to HMRC; or

(in indirect tax cases) either accept the offer of an internal review or notify the appeal direct to the Tribunal.

In income tax, capital gains tax, corporation tax, stamp duty, stamp duty land tax, stamp duty reserve tax, inheritance tax and annual tax on enveloped dwellings cases, however, HMRC have the express permission to accept appeals against their assessments, determinations and amendments more than 30 days after such a decision is made.

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