How to challenge an HMRC penalty or decision: 30 days, reasonable excuses and review without a tribunal

A penalty from HMRC or a bill for the wrong amount is not final. The decision can be challenged, for free and usually without a court. What matters is meeting the deadline and knowing what counts as a reasonable excuse.

What can be challenged?

A penalty — for filing or paying late, for instance. The tax bill itself: Income Tax, Corporation Tax, VAT. A refused claim for tax relief. And a request for information or to check your business records.

How long do you have?

For direct tax, usually 30 days from the date of the decision letter. For indirect tax — VAT, Excise Duty, environmental taxes — the same 30 days run from the date HMRC offers a review. If you need longer on an indirect tax review you can ask for an extension, but the request must come within those 30 days.

What goes in the appeal?

Essential: what you disagree with and why. Worth adding: your name or business name, your reference number such as a Unique Tax Reference, any information HMRC may have missed, and your own figures with the calculation behind them.

What if you miss the deadline?

For direct tax you will need a reasonable excuse. For indirect tax you must ask the tax tribunal to allow a late appeal.

What counts as a reasonable excuse?

The death of a close relative shortly before the deadline. An unexpected hospital stay or serious illness. Computer or software failure while preparing an online return. Problems with HMRC online services. A fire, flood or theft. Unforeseeable postal delays. Delays caused by a disability or mental illness. Not knowing about, or misunderstanding, your legal obligation. And relying on someone else, such as an agent, to send your return when they did not.

What does not count?

A payment that failed for lack of funds. Finding the HMRC online system too difficult. Not receiving a reminder from HMRC. And a mistake you made on the return itself.

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One important addition: once the excuse ends, the return or payment must go in as soon as you are able, not whenever you get round to it.

What happens after you appeal?

A case worker considers it and tries to reach agreement with you — that is how most disputes end. If HMRC does not change its decision, or you cannot agree, you will be offered a review. From that offer you have 30 days either to accept the review or to appeal to the tax tribunal. Reviews are usually quicker than tribunal appeals.

You can also request a review at any time after appealing, without waiting for the outcome — send it to the same HMRC office.

Do you pay while the dispute runs?

You may be able to delay paying the bill or penalty until the matter is resolved. You can also appoint someone to deal with HMRC on your behalf.

Checked against GOV.UK on 27 October 2026.