CIS Appeals: Challenging Gross Payment Status, Deductions And Penalties

Your gross payment status is gone. From the next contract payment, 20% of every invoice—or 30% if you have not been verified—is withheld at source and sent to HMRC instead of to you. That money is still yours; you just cannot touch it until the year-end set-off. For a subcontractor on tight margins, that is not a tax bill—it is a cashflow event that can close the business before any tribunal hears a word.

Or the letter is the other way round: HMRC says you, the contractor, under-deducted from your subcontractors and has raised a Regulation 13 determination—or refused you relief under Regulation 9. Or it is a stack of fixed penalties for late monthly CIS300 returns that snowballed while the contractor or accountant who was supposed to file them went quiet.

Whichever letter you have, it gives you 30 days, and the clock started on the date of the decision, not the date you opened the envelope. Around 45% of people who appeal to the tax tribunal represent themselves. None of what follows is reserved for people with lawyers—but it does depend on working out, today, which of three appellants you are.

What HMRC's Letter Actually Means—And Which Of Three People You Are

The Construction Industry Scheme (CIS) is its own self-contained regime in Part 3, Chapter 3 of the Finance Act 2004 and the Income Tax (Construction Industry Scheme) Regulations 2005 (SI 2005/2045). Its appeal hooks are not the ordinary self-assessment ones, and which hook applies—and what the tribunal is even asked to decide—depends entirely on who you are.

The single most painful feature of CIS: the 20%/30% a contractor withholds is the subcontractor's own money, sitting with HMRC until it is set off against the subcontractor's liabilities at the year end. Freezing a cancelled status during an appeal stops the status changing—it does not refill that cash float, and postponing a contractor's determined liability does not refill it either. Plan for the cashflow gap as a fact, not as something the appeal will reverse.

Before anything else, work out which of three people you are. The hook, the evidence and who can help all flow from this—and The Battlegrounds section below develops each in full:

• The subcontractor whose gross payment status was refused or cancelled. Gross payment status (GPS) lets contractors pay you in full, you accounting for your own tax later. Lose it—a refusal, or more painfully a cancellation under section 66 FA 2004—and every contractor must pay you under deduction. Your appeal hook is section 67 FA 2004, its own route, not section 49 or section 50 TMA 1970. This is why the appeal matters far more than it first looks: once gross status is cancelled, you cannot re-apply for a year, so losing is a minimum twelve-month lockout from gross payment—not a quick re-registration—and the section 67(5) freeze (below) is what keeps your status alive while you fight.
• The contractor facing a Regulation 13 determination. HMRC says you failed to deduct CIS tax and has raised a determination under Regulation 13 of SI 2005/2045, with Regulation 9 as the possible escape. The mechanics—and why this hook is the only one that runs on the TMA assessment machinery—are below.
• Anyone arguing CIS does not apply at all. Sometimes the real fight is scope: is the work a "construction operation" within section 74 FA 2004, or were the workers employees, so PAYE—not CIS—should have applied? This cuts across all three appellant types and is the most fact-sensitive part of the regime.

Each decision arrives as a distinct notice, and the heading plus the legislative reference tell you which you are holding: a GPS refusal or cancellation cites section 66 and states an effective date; a Regulation 13 notice of determination states an amount and a pay-by line; a Regulation 9 refusal notice states the grounds and a date; a Schedule 55 penalty arrives as a penalty notice or assessment. Identify the document before you do anything else.

Two points apply to everyone before the battlegrounds: the 30-day clock and the personal-liability trap.

The 30-Day Clock (Three Different Statutory Hooks)

Every route has a 30-day deadline, but the hook differs:

• GPS refusal or cancellation: notice of appeal to HMRC within 30 days of the refusal or cancellation, stating why registration should not have been refused or cancelled (s.67(2)–(3) FA 2004).
• Regulation 9 refusal notice: notice to an officer within 30 days, specifying the grounds (reg 9(7)).
• Regulation 13 determination: the TMA appeal machinery imported by reg 13(5)—a written appeal within 30 days, with the ordinary statutory-review and tribunal routes that follow.

Miss any of these and you are into a late-appeal application, which the tribunal does not grant routinely—the test is the three-stage Martland framework (see late appeal to the tax tribunal and Martland v HMRC). File something in time even if full grounds follow later.

The Personal Liability Trap [Subcontractor]

A GPS cancellation attaches to you, the subcontractor as registered. If a payroll bureau or accountant caused the compliance failures, that is a separate matter for a solicitor on the negligence side: the professional-negligence clock under the Limitation Act 1980 (broadly six years from the damage under section 2, with a latent-damage extension under section 14A) runs independently of the tax appeal. It is a signpost, not a tribunal issue—flag it early even if you decide later not to pursue it.

How CIS Actually Works (And Why The Numbers Hurt)

Under section 61 FA 2004, a contractor must deduct "the relevant percentage" from a contract payment, excluding the part representing the direct cost of materials. The rate is set by Treasury order under s.61(2) and capped by s.61(3): 0% with gross payment status; 20% if registered and verified but not gross; 30% if not registered or not verified.

To hold gross payment status, Schedule 11 FA 2004 sets three tests, applied by appellant type (individuals, firms, companies):

• The business test — you carry on (or are about to carry on) a UK construction business, run mainly through a bank account.
• The turnover test — net construction turnover at or above £30,000 per relevant person, or an alternative aggregate threshold of £200,000 for firms and companies (SI 2005/2045 reg 28(2)/(3)).
• The compliance test — you complied, in the 12 months reviewed, with your CIS, PAYE, self-assessment, corporation tax and VAT obligations. Prescribed minor failures are disregarded, and a failure for which there was a reasonable excuse (the obligation then met without unreasonable delay) is treated as compliance.

HMRC does not test this once. It runs an automated annual compliance review—the Tax Treatment Qualification Test—as an annual review of whether you still pass the Schedule 11 compliance test, and a run of late PAYE or CIS payments caught by that review is the most common cancellation trigger. Contractors, meanwhile, must file a monthly CIS300 "within 14 days of the end of every tax month" (SI 2005/2045 reg 4)—the month ends on the 5th, so the deadline is the 19th of the month, with a nil return still required where there were no payments.

The cashflow worked example. A subcontractor invoices £10,000 (labour, no materials) and loses gross status. The contractor withholds 20%—£2,000—and pays £8,000. That £2,000 is not lost: it sits with HMRC and is set against your tax and Class 4 NIC at the year end. But across £200,000 of annual invoicing, £40,000 has left your hands months before set-off. Winning the appeal restores the status going forward; the float built up meanwhile returns only through the normal year-end reconciliation, not as a refund for winning. That reconciliation is concrete: a sole trader sets the deductions against the income tax and Class 4 NIC on the self-assessment return and is repaid any excess; a company sets them against its PAYE and CIS liabilities or reclaims the balance after the tax year.

"But Losing Gross Status Will Ruin My Business"

This is the instinct almost every subcontractor has, and it is the one argument that has already been tested at the highest level and lost.

Why Business Impact Does Not Count (J P Whitter)

In J P Whitter (Water Well Engineers) Ltd v HMRC [2018] UKSC 31, a family water-well engineering business trading since 1972, with around 25 employees and turnover of about £4.4 million, had its gross payment status revoked on 30 May 2011 for a history of late PAYE without reasonable excuse. The First-tier Tribunal found cancellation "would have been likely to lead to the loss of around 60% of the company's turnover, and the dismissal of about 80% of its employees, and that recovery would be expected to take about ten years"—and HMRC had taken no account of that.

That argument still lost. Lord Carnwath held, at [21], that "any statutory discretion must be exercised consistently with the objects and scope of the statutory scheme"—and, at [22], that he could not read the section 66 power "as extending to matters 'which do not relate, directly or indirectly, to the requirements for registration for gross payment, and to the objective of securing compliance with those requirements'." In the Court of Appeal below (J P Whitter (CoA) [2016] EWCA Civ 1160, para 60), Henderson LJ had already held that the financial impact of cancellation "would fall well outside the intended scope of the power". The Court also rejected registration as a "possession" giving proportionality protection: at [23], rights conferred by registration "cannot extend beyond the limits set by the legislation by which they are created," and any interference was proportionate. The appeal was dismissed. The full procedural history, each stage linked: First-tier Tribunal J P Whitter (FTT) [2012] UKFTT 639 (TC) (the taxpayer won there), Upper Tribunal J P Whitter (UT) [2015] UKUT 392 (TCC), Court of Appeal J P Whitter (CoA) [2016] EWCA Civ 1160, Supreme Court J P Whitter [2018] UKSC 31.

The lesson is blunt. "Cancellation will destroy my business, so it must count" is precisely the argument the Supreme Court rejected. Business impact does not feature in the section 66 decision.

What The Tribunal Actually Decides—And When (RMF Construction)

So what does the tribunal decide? It hears the GPS appeal afresh, but the question is whether HMRC's decision was correctly reached on the circumstances as they stood at the date HMRC made it. In The Commissioners for HM Revenue and Customs v RMF Construction Services Ltd [2022] UKUT 67 (TCC) (GOV.UK Tax and Chancery decision), the Upper Tribunal held the tribunal has no power to take subsequent changes into account—cleaning up your compliance after the decision does not rescue the appeal.

That has a hard consequence. This is not an open-ended rehearing, and not the "assessment stands unless you displace it" model used for self-assessment closure notices. Gather evidence about the position during the relevant compliance period and as at the date of HMRC's decision—later good behaviour, however genuine, will not turn the appeal.

When The Compliance History Still Helps

Within those limits, three arguments are genuinely winnable: that the compliance failure did not occur, or fell within the disregarded-minor category; that you had a reasonable excuse under Schedule 11 (for companies, para 12(3)); or that HMRC got the facts or figures wrong. The reasonable-excuse argument runs on the same four-step framework used across this site—see what is a reasonable excuse? and Perrin v HMRC—and the CIS case law on it is set out under The Battlegrounds below.

The Battlegrounds

CIS letters rarely say "battleground", but the wording almost always maps to one of these. Use this decoder before drafting anything.

The Compliance, Business And Turnover Tests [Subcontractor]

Most GPS cancellations are fought on the compliance test. The section 66 power is discretionary: in Scofield v HMRC [2011] UKFTT 199 (TC), the tribunal held "may" in section 66 confers a discretion HMRC must exercise properly—it is not automatic that a compliance failure ends gross status. Connaught Contracts (Bennett) v HMRC [2010] UKFTT 545 (TC) is another compliance-test and reasonable-excuse example. The reasonable-excuse limb (Sch 11 para 12(3) for companies) is the live battleground in most cancellation appeals; Bruns (t/a TK Fabrications) v HMRC [2010] UKFTT 58 (TC) and Wood (t/a Propave) v HMRC [2011] UKFTT 136 (TC) illustrate it—but both predate J P Whitter, so cite them only for the reasonable-excuse point, not the business-impact reasoning that no longer survives.

The business and turnover tests, by contrast, are arithmetical—was there a genuine UK construction business run through a bank account, and did net construction turnover reach the £30,000 / £200,000 thresholds set out earlier? Check how HMRC computed turnover before assuming the test is failed.

Regulation 13 And The Regulation 9 Escape [Contractor]

A Regulation 13 determination quantifies, on the officer's best judgment, what the contractor should have deducted. The escape is Regulation 9. Condition A (reg 9(3)) is about your conduct: you satisfy an officer that you took reasonable care to comply with section 61 and the Regulations, and the failure to deduct was either an error in good faith or a genuine belief that section 61 did not apply. Condition B (reg 9(4)) is about the subcontractor: the officer is satisfied the payee was not chargeable on the payments, or returned them and paid the tax and Class 4 NIC (or corporation tax) due—and you request a direction.

The appealable points differ. A refused Condition A direction comes as a reg 9(6) refusal notice, appealable under reg 9(7) within 30 days on the reg 9(8) grounds (which mirror Condition A). Condition B has no parallel refusal-notice appeal—it is operated on a contractor request, so your leverage is documentary: evidence the subcontractor's return and payment. In practice the contractor's appealable decisions are the reg 9(6) refusal notice and the Regulation 13 determination itself.

If you are the subcontractor in someone else's Regulation 13 fight [Subcontractor]. HMRC does not assess you under Regulation 13—the determination is the contractor's liability, not yours. But your position is decisive to the contractor's Condition B escape: if you returned those payments and paid the income tax and Class 4 NIC (or corporation tax) on them, that is exactly what unlocks the direction and stops HMRC collecting the same tax twice. If a contractor tells you HMRC is pursuing a determination on payments made to you, keep your filed returns and payment evidence to hand—your own compliance is part of the answer, and you should not assume the dispute has nothing to do with you.

Construction Operations And Employment Status [All]

Section 74 works by two lists. Section 74(2) is the included "mainstream" list—construction, alteration, repair, extension or demolition of buildings or structures; works to the land; installing heating, lighting, water and drainage; site cleaning during construction; painting and decorating. Section 74(3) is the excluded list—off-site manufacture and delivery of components; professional work of architects and surveyors; wholly artistic works; signwriting; installing blinds, shutters and security systems such as CCTV. Whether a given job is in or out is intensely fact-specific and litigated at the margins—mixed contracts and manufacture-then-install arrangements are the classic flashpoints. This guide explains the structure; it cannot tell you whether your job is in or out, and a genuine scope dispute is what the tribunal exists to resolve.

The employment-status overlap is adjacent but different. If HMRC decides your "subcontractors" were really employees, the result is a PAYE/NIC determination and a deemed-employment analysis—a separate appeal, though it can run alongside a GPS or Regulation 13 dispute. The legal test is the same multi-factor employment test as IR35, covered in IR35 and off-payroll appeals and PGMOL v HMRC. We do not re-run that analysis here—follow those links if status is the real fight.

Burden Of Proof And The Standard Of Review

There is no single answer. The three appellants face three different questions.

GPS appellant (section 67). The tribunal hears the appeal afresh, but on the circumstances as at the date HMRC made its decision (RMF Construction)—it cannot weigh later events. Combined with J P Whitter, business impact is irrelevant; only the Schedule 11 conditions and the compliance facts matter, and on a reasonable excuse (Sch 11 para 12(3)) you must establish the excuse on the Perrin framework. John Kerr Roofing Contractors v HMRC [2013] UKFTT 135 (TC) confirmed the FTT has jurisdiction under s.67(4) FA 2004 to review HMRC's section 66 discretion (its impact-based ground is now bad law after J P Whitter). This is not a "deemed correct unless displaced" assessment; it is a status decision.

Regulation 13 determination (contractor). By reg 13(5) the determination is treated as an assessment under TMA Parts 4 to 6, so the section 50(6) TMA 1970 burden applies in the ordinary way—the determination stands unless you displace it. You bear the burden on quantum and on the Regulation 9 Condition A escape (the reg 9(8) grounds mirror Condition A and it is for you to satisfy the officer or tribunal). This is the only place section 50(6) applies, and it applies because reg 13(5) imports it into CIS—not as a generic TMA route.

Penalties (Schedule 55/24/41). HMRC must first establish the penalty is due—that the failure or inaccuracy occurred and the assessment is procedurally valid. Only then does the burden move to you on reasonable excuse (Sch 55 para 23) or special circumstances. Do not collapse these three answers into one.

Penalties: Late CIS300 Returns And Inaccuracies

Late monthly returns are penalised under Schedule 55 FA 2009, on the CIS row (separate from the self-assessment rows):

• £100 — initial fixed penalty when the CIS300 is not filed by the deadline.
• £200 — a further fixed penalty when it is still outstanding two months after the penalty date.
• £300 (or 5% of the deductions, if higher) — at 6 months, and again at 12 months, the greater of £300 or 5% of the deductions shown on the return (with higher tax-geared figures where information is withheld deliberately).

These compound fast—a contractor who files nothing for months faces four-figure penalties on one return cycle. There is statutory relief for a brand-new contractor: Schedule 55 FA 2009, para 13(2)(b) caps the aggregate of the fixed penalties under paragraphs 8 and 9 (the £100 and £200 elements) at £3,000 for the CIS300 returns required up to and including the contractor's first return. This is the CIS-specific cap—not the self-assessment tax-geared cap. The reasonable-excuse defence in Sch 55 para 23 applies to all of these, on the same four-step Perrin framework—see self-assessment penalties, HMRC penalties explained and the new penalty regime.

Beyond late filing: an inaccurate CIS return or under-deduction can attract a behaviour-based penalty under Schedule 24 FA 2007, and an unregistered contractor a failure-to-notify penalty under Schedule 41 FA 2008. As with the entrepreneur-relief cluster—see R&D tax credit appeals and BADR appeals—the company or contractor can be liable even where a payroll bureau or adviser did the work; adviser failure does not automatically transfer liability.

If The Contractor Or Adviser Has Gone Quiet

A common pattern: the payroll bureau or accountant filing your CIS300s stopped responding and the penalties stacked up while you waited. Beyond protecting the 30-day deadline (in the action list below), the evidential reconstruction is what wins these:

1. Request your records in writing. Ask for every CIS300, payment record and HMRC letter on file. The documents are yours even if fees are owed; the unanswered-request trail also helps any later negligence claim.
2. Reconstruct the return history from HMRC's own filing and payment record, so you can see which returns were genuinely late and why.
3. Test the reasonable-excuse line. Whether reliance on a non-responsive agent is a reasonable excuse is fact-specific—the Perrin framework and the same point in our Martland, BADR and EIS/SEIS guides apply: the tribunal looks at what you did, not just the adviser.
4. Flag the negligence clock. If the bureau's failure caused the loss, the Limitation Act 1980 clock runs independently of the tax appeal—raise it with a solicitor early.

How The Appeal Works

Each appellant files a written appeal within 30 days on the hook set out under The 30-Day Clock above: section 67 (GPS), reg 9(7) (refusal notice, on the reg 9(8) grounds), or the reg 13(5) TMA route. The GPS appellant has one crucial protection: under section 67(5) FA 2004, where registration is cancelled and you appeal, the cancellation does not take effect until the appeal is finally determined or abandoned—your gross status is frozen while the appeal runs (J P Whitter confirmed this verbatim at [3]). On a reg 9(7) appeal, the tribunal can direct an officer to make the reg 9(5) direction if it considers the refusal notice should not have been issued.

After the written appeal, all three converge on the standard spine. You can ask for a free statutory review by a different officer—see HMRC internal review—or notify the appeal to the First-tier Tribunal directly. Filing and tribunal mechanics, including case tracks and costs risk, are in how to appeal to the tax tribunal, tribunal tracks and costs, and the tax dispute timeline; for drafting the grounds, see writing grounds of appeal.

The critical caveat on money: section 67(5) freezes a cancelled status only—it does not refund or stop the 20%/30% deductions, and in a refusal case there is no status to freeze, so the float builds from the start. For a Regulation 13 determination, section 55 TMA 1970 postponement can stop collection of the determined sum pending appeal—but interest still runs on it, because reg 13(5) imports the TMA charging machinery, so postponement pauses collection, not the accruing interest. See postponing payment during appeal and interest on unpaid tax. Both devices pause an outflow; neither hands the cash back.

Key Differences From Income Tax Self-Assessment Appeals

CIS is a self-contained regime. Every appeal hook and standard of review differs from ordinary self-assessment.

What Evidence You Need On Day One

The letter tells you which battleground HMRC has picked. Pull the evidence that goes to that fight—and, for GPS, evidence about the position as at the date of HMRC's decision and the relevant compliance period:

• The HMRC letter, with its legislative reference (s.66/s.67, reg 9, reg 13 or Sch 55) and decision date.
• Your full CIS and tax compliance history for the period reviewed—CIS300 returns, PAYE/RTI, self-assessment or corporation tax, VAT, and the dates of every payment—plus anything evidencing a reasonable excuse (what went wrong, when, how quickly the obligation was met once it ended).
• Turnover and bank evidence if the business or turnover test is in issue—management accounts and how net construction turnover was computed.
• For a Regulation 13 / Regulation 9 fight—verification records, deduction statements, the contracts, and (for Condition B) evidence the subcontractor returned and paid the tax; for a scope dispute, the contracts and what was actually done.
• Correspondence with any agent or bureau, including written record requests that went unanswered.

Six Things To Do This Week

1. Work out which appellant you are. GPS subcontractor, Regulation 13/Regulation 9 contractor, or a scope/status dispute. The legislative reference on the letter decides it.
2. Diarise the 30-day deadline from the decision date, not the date you opened the letter—and note the hook (s.67, reg 9(7), or the reg 13(5) TMA route).
3. File a protective written appeal now. A short holding appeal stops the clock; full grounds can follow. For a GPS cancellation, this also engages the section 67(5) freeze on your status.
4. Plan for the cashflow gap as a fact. Section 67(5) and section 55 postponement pause outflows; neither refunds the withheld float. Build the gap into your forecasts.
5. Gather the evidence that goes to HMRC's actual battleground, focusing—for GPS—on the position at the decision date, because later good behaviour will not turn the appeal.
6. Get independent advice with no stake in the outcome. A Chartered Tax Adviser via CIOT's Find a CTA directory, a chartered accountant via ICAEW's directory, or a specialist tax barrister via the Bar's Public Access Scheme. If cost is the barrier, the charities TaxAid and Tax Help for Older People advise those who cannot afford a professional, and Advocate can find free barrister help. See writing grounds of appeal before you draft.

Key Legislation And Resources

Legislation

• Finance Act 2004, Part 3, Chapter 3 — the Construction Industry Scheme (ss.57–77)
• Section 61, FA 2004 — deductions on account of tax from contract payments
• Section 66, FA 2004 — cancellation of registration for gross payment
• Section 67, FA 2004 — registration for gross payment: appeals (including the s.67(5) freeze)
• Section 74, FA 2004 — meaning of "construction operations"
• Schedule 11, FA 2004 — conditions for registration for gross payment (business / turnover / compliance tests)
• SI 2005/2045 — esp. reg 4 (monthly return), reg 9 (recovery from subcontractor; Conditions A & B; refusal-notice appeal), reg 13 (determination; TMA Parts 4–6 imported), reg 28 (minimum turnover £30,000 / aggregate £200,000)
• Schedule 55, FA 2009 — late CIS300 penalties
• Schedule 24, FA 2007 — inaccuracy penalties
• Schedule 41, FA 2008 — failure-to-notify penalties
• TMA 1970 — esp. s.50 (burden) and s.55 (postponement), as imported for Reg 13 by reg 13(5)
• Limitation Act 1980 — negligence claim against an adviser (signpost only)

Key Cases

• J P Whitter (Water Well Engineers) Ltd v HMRC [2018] UKSC 31 — HMRC need not weigh the business impact of cancelling GPS under s.66; the s.66 discretion is bounded by the objects and scope of the statutory scheme; A1P1/proportionality argument rejected. (Procedural history, all stages linked: FTT J P Whitter (FTT) [2012] UKFTT 639 (TC); UT J P Whitter (UT) [2015] UKUT 392 (TCC); CoA J P Whitter (CoA) [2016] EWCA Civ 1160.)
• The Commissioners for HM Revenue and Customs v RMF Construction Services Ltd [2022] UKUT 67 (TCC) — a GPS appeal is judged on the circumstances as at the date HMRC made its decision; the FTT cannot take subsequent changes into account.
• Scofield v HMRC [2011] UKFTT 199 (TC) — "may" in s.66 confers a discretion HMRC must exercise properly.
• Bruns (t/a TK Fabrications) v HMRC [2010] UKFTT 58 (TC) — reasonable excuse to the compliance test (business-impact reasoning superseded by J P Whitter; cite only for the reasonable-excuse point).
• Wood (t/a Propave) v HMRC [2011] UKFTT 136 (TC) — reasonable excuse, Sch 11 para 12(3) (same J P Whitter caveat).
• John Kerr Roofing Contractors v HMRC [2013] UKFTT 135 (TC) — FTT jurisdiction under s.67(4) FA 2004 (impact ground now bad law post-J P Whitter).
• Connaught Contracts (Bennett) v HMRC [2010] UKFTT 545 (TC) — CIS GPS reasonable excuse / compliance test.
• Employment-status overlap: see PGMOL v HMRC [2024] UKSC 29 and IR35 and off-payroll appeals (Ready Mixed Concrete, Hall v Lorimer).

HMRC Guidance

• CIS 340 — Construction Industry Scheme: a guide for contractors and subcontractors
• HMRC Construction Industry Scheme Reform manual (CISR) — esp. the GPS cancellation, appeals and scheduled-review (TTQT) series
• Tax and Chancery Tribunal decisions — Upper Tribunal, official

On This Site

• IR35 and off-payroll appeals — the CIS-vs-employee status overlap
• PGMOL v HMRC: employment status — the multi-factor employment test
• What is a reasonable excuse? — the general framework
• Perrin v HMRC — the four-step reasonable excuse test
• HMRC penalties explained — Schedule 24 and the penalty framework
• Self-assessment penalties — Schedule 55 penalty mechanics
• New penalty regime — the FA 2021 points-based and percentage penalties
• Postponing payment during appeal — section 55 TMA on a Regulation 13 sum
• Interest on unpaid tax — interest runs on a Regulation 13 determination
• How to appeal to the tax tribunal — step-by-step filing
• HMRC internal review — the free review step before the tribunal
• Writing grounds of appeal — drafting s.67 / reg 9 / reg 13 grounds
• Late appeal to the tax tribunal — if the 30-day window slipped
• Martland v HMRC: late appeals — the three-stage late-appeal test
• Tribunal tracks and costs — case categories and costs risk
• Tax dispute timeline — where CIS appeals sit in the broader journey
• R&D tax credit appeals · BADR appeals · EIS/SEIS relief appeals — the adviser-gone-quiet cluster pattern

This article is for informational purposes only and does not constitute legal or tax advice. For advice specific to your situation, consult a qualified tax adviser, accountant, or solicitor.