A Practical Guide to Tax Appeals

1. The New Tribunal System;
2. How Appeals Begin-Indirect Taxes;
3. How Appeals Begin - Direct Taxes;
4. The Enquiry Process for Indirect and Direct Taxes;
5. HMRC's Information Powers;
6. Obtaining a Closure Notice;
7. Internal Reviews and Appeals;
8. General Powers of the FTT;
9. Allocation of Appeals;
10. Disclosure;
11. Lead Cases;
12. Taxpayer Confidentiality and Privacy;
13. Case Preparation before the FTT;
14. Striking out a Party's Case;
15. Advocacy;
16. The Hearing before the FTT;
17. Appeals from the FTT;
18. General Powers of the UT;
19. The Hearing before the UT;
20. Appeals from the UT;
21. In the Court of Appeal;
22. Appeals from the Court of Appeal
23. In the Supreme Court;
24. Costs;
25. Human Rights;
26. Alternative Dispute Resolution;
27. Judicial Review;
28. European Law and References to the CJEU;

APPENDICES
Appendix 1 Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules
2009;
Appendix 2 Tribunal Procedure (Upper Tribunal) Rules 2008;
Appendix 3 Practice Directions and Practice Statements;
Appendix 3A - In the Supreme Court of England and Wales Direction:

Classes of Cases specified under section 18(6) of the Tribunals, Courts
and Enforcement Act 2007;
Appendix 3B - Practice Direction: Upper Tribunal Transcripts of Proceedings;
Appendix 3C - Practice Direction: First-tier and Upper Tribunal Use of
the Welsh Language in Tribunals in Wales;
Appendix 3D - Practice Direction: First-tier Tribunal Categorisation of
Cases in the Tax Chamber;
Appendix 3E - Practice Direction: Delegation of Functions to Staff in
Relation to the Tax Chamber of the First-tier Tribunal and the Finance and
Tax Chamber of the Upper Tribunal on or after 1 April 2009;
Appendix 3F - Practice Direction: Composition of Tribunals in Relation
to Matters that Fall to be Decided by the Tax Chamber of the First-tier
Tribunal and the Finance and Tax Chamber of the Upper Tribunal on or
after 1 September 2009;
Appendix 3G - Practice Direction: Form of Decisions and Neutral
Citation First-tier Tribunal and Upper Tribunal on or after 3 November
2008;
Appendix 4 Notice of Appeal and Tribunal Guidance;
Appendix 4A - Notice of Appeal to the Tax Chamber of the First-tier
Tribunal;
Appendix 4B - Guidance Notes on Completing the Notice of Appeal;
Appendix 4C - At Your Hearing - Explanatory Booklet;
Appendix 4D - Guidance to accompany a Decision from the First-tier
Tribunal (Tax Chamber);
Appendix 4E - First-tier Tribunal Application for Permission to Appeal to
the Upper Tribunal;
Appendix 4F - Guidance notes on completing the First-tier Tribunal
Application for Permission to Appeal to the Upper Tribunal;
Appendix 4G - Application to Close Enquiry;
Appendix 5 Civil Procedure Rules, Part 52 and Practice Directions 52A,
52C and 52D;
Appendix 5A - Civil Procedure Rules, Part 52;
Appendix 5B - Practice Direction 52A;
Appendix 5C - Practice Direction 52C;
Appendix 5D - Practice Direction 52D;
Appendix 6 Pre-Action Protocol for judicial review, Civil Procedure Rules,
Part 54 and Practice Directions 54A and 54D;
Appendix 6A - Pre-Action Protocol for Judicial Review;
Appendix 6B - Civil Procedure Rules, Part 54;
Appendix 6C - Practice Direction 54A;
Appendix 6D - Practice Direction 54D;
Appendix 7 Civil Procedure Rules, Part 68 and Practice Direction 68;
Appendix 7A - Civil Procedure Rules, Part 68;
Appendix 7B - Practice Direction 68;
Index