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 ³Õ5.400¹ó–V5.400°
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