When the tribunal considers whether to permit a late appeal or a late notification of an appeal it applies the principles set out in the Upper Tribunal case of Martland. This article looks at what this means in practice and other key cases to be aware of. It also reflects on recent tribunal decisions about late appeals and what we can learn from them.

Appealing late

When a taxpayer wishes to appeal against an HMRC decision they should respond within 30 days. The process for appealing differs depending on whether the decision concerns direct or indirect tax and the impact of the internal review process.