HMRC’s reviews and appeals

HMRC’s Reviews and appeals: 2013/14 contains statistics showing the outcome of reviews and appeals against HMRC tax decisions for the year 1 April 2013 to 31 March 2014. It covers both internal reviews and appeals resolved with or without a tribunal hearing.

The statistics are, of course, presented in a way which highlights HMRC’s successes, such as the fact that three-quarters of decisions made by the tribunal in 2013/14 were in HMRC’s favour. However, presenting the data in another way is instructive:

• Of the 38,621 HMRC decisions reviewed in 2013/14, 49% were either varied or cancelled;
• 44% of the 4,076 appeals concluded before a tribunal hearing were decided in the taxpayer’s favour; and
• 607 of the 2,550 appeals that did proceed to a tribunal hearing were decided wholly or partly in the taxpayer’s favour.

These statistics are best demonstrated by a simple table:

In total, therefore, HMRC made 21,235 mistaken ‘decisions’ in 2013/14, which amounts to almost half of all cases reviewed or appealed. This is a remarkable statistic, particularly noting that the original decisions would have been made by HMRC following lengthy interaction with the taxpayer and internal review within HMRC.