A5.611 Upper Tribunal—function
Where a taxpayer disputes an HMRC decision, they must first make an appeal to HMRC (except in relation to indirect taxes including VAT where no obligation to first appeal to HMRC exists) and then, if the matter cannot be resolved, may notify the appeal directly to the First-tier Tribunal. See A5.605–A5.610 and De Voil Indirect Tax Service V5.400F–V5.400K for details of appeals to the First-tier Tribunal.
Once the First-tier Tribunal has issued a decision with full reasons, either party (or both) may wish to appeal the decision to the Upper Tribunal.
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