A review conclusion letter tells you whether HMRC’s review officer has upheld, varied or cancelled the decision you disputed, and why. If the decision is upheld or varied and you still disagree, you normally have 30 days from the date of the letter to notify your appeal to the tax tribunal; if you do nothing, a direct tax dispute is treated as settled on the review officer’s terms.
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What is a review conclusion letter?
A statutory review is a fresh look at a disputed HMRC decision by an officer who was not involved in making it. For direct taxes such as Income Tax, Capital Gains Tax and Corporation Tax, the rules are in section 49A onwards of the Taxes Management Act 1970 (TMA 1970). Section 49E(6) requires HMRC to notify you of the conclusions of the review and their reasoning within 45 days, or within another period you agree. Where you asked for the review, the 45 days start on the day HMRC notified you of its view of the matter; where HMRC offered the review, they start on the day HMRC received your acceptance (section 49E(7)).
The letter that delivers those conclusions is what HMRC’s Appeals, Reviews and Tribunals Guidance calls the conclusion of review letter. It is the document that starts your next deadline, so its date is the most important thing on it. If you are earlier in the process, see accepting an offer of statutory review.
What outcomes can the review reach?
Section 49E(5) TMA 1970 gives three possible conclusions. HMRC’s guidance at ARTG4810 explains each:
| Conclusion | What it means | Example given by HMRC |
|---|---|---|
| Upheld | The decision you disagreed with stands | The amount of the assessment and the reasons for it are unchanged |
| Varied | The decision is changed in some way | The assessment is amended, or the reasons for it change |
| Cancelled | The decision is not appropriate | The assessment is withdrawn |
For penalties under Schedule 24 to the Finance Act 2021, section 49E(5A) points to section 49EA, which allows additional conclusions. A varied decision can go either way, so read the figures carefully: a variation is not necessarily a reduction.
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What must the letter tell you?
ARTG4820 says that whatever the outcome, the review officer writes to you with their conclusions, copying the decision maker, and where an agent acts the letter goes to you with a copy to the agent. The letter must tell you the review officer’s decision, explain the reasons for it and say what will happen next. If the decision is upheld or varied, the letter must also:
- explain your options, including appealing to the tribunal if you disagree;
- explain the relevant time limits;
- explain the implications for any postponement or other suspension of tax; and
- explain the consequences if you take no action.
If those reasons are thin, that is worth noting for the tribunal, but it does not stop the clock. HMRC’s guidance at ARTG4860 says you are entitled to a review only once and there is no legal basis for a second review, even if you provide new information.
How long do you have to go to the tribunal?
For direct taxes, section 49G(5)(a) TMA 1970 defines the post review period as 30 days beginning with the date of the document in which HMRC give notice of the conclusions. That is the date printed on the letter, not the date you received it. You notify the appeal to the First tier Tribunal, not to HMRC, and the tribunal’s procedure rules require a notice of appeal giving the decision appealed against, the result you want and your grounds, with a copy of the decision and any statement of reasons (rule 20 of the Tribunal Procedure (First tier Tribunal) (Tax Chamber) Rules 2009). See the tax tribunal notice of appeal for the form and content.
For VAT, section 83G(3) of the Value Added Tax Act 1994 says that where HMRC are required to carry out a review, any appeal must be made within 30 days beginning with the conclusion date, which section 83G(7) defines as the date of the document notifying the conclusions. The GOV.UK guidance on disagreeing with a tax decision gives the same message: if you disagree with the result of the review, you must usually appeal to the tax tribunal within 30 days of the date on the review result letter.
What if you miss the 30 days?
Once the post review period has ended, section 49G(3) allows a direct tax appeal to be notified only if the tribunal gives permission, and section 83G(6) VATA 1994 does the same for VAT. Rule 20(4) of the tribunal rules says a late notice of appeal must include a request for permission and the reason it was not provided in time, and the tribunal must not admit the appeal unless permission is given. Permission is not automatic, so treat the 30 days as a hard limit.
What happens if you do nothing?
For direct taxes, section 49F(2) treats the conclusions as if they were a written agreement under section 54(1) settling the matter, and section 49F(3) prevents you from using the usual right to resile from such an agreement. That deemed agreement falls away only to the extent that you notify the appeal to the tribunal under section 49G. ARTG4830 says that if the customer does not reply within 30 days, or HMRC do not hear within 45 days that an appeal has been notified, the matter is final, subject to any late appeal. For indirect taxes, the guidance says the review officer tells the decision maker to close the case in line with the conclusions.
If the review cancels HMRC’s decision, ARTG4840 says the decision maker must take the action needed to give effect to the conclusions, and the GOV.UK guidance says you do not need to do anything.
What if the letter never arrives?
If HMRC do not notify conclusions within the 45 days or agreed period, section 49E(8) treats the review as having upheld HMRC’s view, and section 49E(9) requires HMRC to tell you so. Under section 49G(5)(b), you can then notify the appeal at any time from the day after the review period ends until 30 days after the date of HMRC’s notice of the deemed conclusion. This is covered in when HMRC misses the 45 day review deadline.
What about paying the tax?
The GOV.UK guidance says that if the review officer upholds or varies the decision and you agree with the outcome, you need to pay whatever you owe, and interest can run on tax in dispute until it is paid. ARTG4830 notes that when you appeal to the tribunal on a direct tax matter you may ask the decision maker to postpone the tax charged or vary the amount already postponed. For VAT the position is stricter: section 84(3) VATA 1994 says certain appeals will not be entertained unless the VAT HMRC have determined to be payable has been paid or deposited, unless HMRC or the tribunal accept that paying would cause hardship. See the VAT pay first rule.
How do the dates work, and what goes wrong?
Illustration only. A review conclusion letter upholding a discovery assessment is dated 3 November 2026 and reaches the taxpayer on 9 November. The 30 days begin with 3 November, so the last day to notify the tribunal is 2 December 2026. Counting from 9 November would give 8 December, which would be six days late and would need the tribunal’s permission.
Common mistakes include:
- counting from the date the letter arrives rather than its date;
- writing back to the review officer instead of notifying the tribunal;
- asking HMRC for a second review, which the guidance says is not available;
- assuming a varied decision means less tax without checking the figures; and
- overlooking postponement, so that HMRC begin collecting tax that is still in dispute.
For the wider route from review to hearing, see HMRC statutory reviews and the tax tribunal.
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Related Accountapedia entries
- HMRC Statutory Review and the Tax Tribunal
- HMRC’s view of the matter letter
- Judicial review of HMRC decisions
- Parent company letters of support
- What happens if you ignore an HMRC enquiry letter
Sources
- legislation.gov.uk: Act 1970 c. 9, section 49E
- GOV.UK: Manual page ARTG4810
- GOV.UK: Manual page ARTG4820
- GOV.UK: Manual page ARTG4860
- legislation.gov.uk: Act 1970 c. 9, section 49G
- legislation.gov.uk: SI 2009/273, article 20
- legislation.gov.uk: Act 1994 c. 23, section 83G
- GOV.UK: Print
- legislation.gov.uk: Act 1970 c. 9, section 49F
- GOV.UK: Manual page ARTG4830
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.