Appealing CT600 and current VAT penalties

This guide covers ordinary CT600 late-filing penalties and VAT late-submission points or financial penalties and VAT late-payment penalties for VAT accounting periods beginning on or after 1 January 2023. It explains how to identify the relevant route, deadline, evidence and next decision stage. It is not an appeal form, legal opinion or prediction of success.

An HMRC penalty appeal is not one uniform process. Corporation Tax is a direct tax: appeal the decision to HMRC first. VAT is an indirect tax: the decision letter normally offers an HMRC review or an appeal to the First-tier Tribunal. Read the actual notice before using either route. PAYE, Self Assessment, inaccuracy and information-notice penalties, old VAT default surcharges, and interest disputes are outside this guide.

For a CT600 late-filing penalty, use the Corporation Tax penalty notice and HMRC's direct-tax appeal route. HMRC's Company Tax Return guidance provides an online appeal for a reasonable excuse and says the return must be filed first. The COTAX manual also recognises disputes about the filing date, accounting period, notice and penalty calculation; a reasonable-excuse narrative is not the only possible issue.

For VAT periods beginning on or after 1 January 2023, late submission can produce points and, at the threshold, a financial penalty. Late payment is a separate penalty regime and is not the same as late-payment interest. The VAT decision letter offers review or Tribunal choices; the VAT online account and official guidance explain how to challenge points or penalties. Older VAT default-surcharge periods need their own historical rules and are not covered here.

HMRC's general penalty page says an appeal is usually made within 30 days of the penalty being issued. For direct tax, the decision guidance describes 30 days from the date of HMRC's decision letter to appeal to HMRC. For an indirect-tax decision such as VAT, the review offer gives 30 days to accept a review or appeal to the Tribunal. After a review conclusion there is a separate Tribunal clock. These are related but not a universal '30 days from receipt' rule.

Act promptly and follow the actual notice. A late appeal is not automatically accepted: HMRC's direct-tax guidance considers the reason for delay and whether the appeal followed without unreasonable further delay; the Tribunal can decide whether to permit a late appeal. Do not assume a review request extends every other deadline without checking the applicable route.

HMRC considers reasonable excuse for some late-filing and late-payment failures. Its guidance treats the circumstances individually, including how the event prevented compliance and whether the taxpayer put matters right without unreasonable delay after it ended. Serious illness, bereavement or HMRC service failure can be relevant; none guarantees an outcome.

Check the precise penalty and ground. A wrongly stated CT600 filing date or VAT point history is a factual or calculation dispute, not necessarily a reasonable-excuse claim. Special reduction in some regimes and suspension of some careless-inaccuracy penalties are distinct statutory concepts, not interchangeable fallback grounds for these two supported procedures. Reliance on an accountant by itself normally does not establish reasonable excuse; HMRC considers whether reasonable care was taken in the circumstances.

Keep the penalty notice, period and decision date, relevant return acknowledgements, payment records and HMRC correspondence. If an external event is relevant, record when it began and ended, precisely how it prevented compliance, what alternative steps were attempted and when the failure was corrected. Medical, outage or software records may corroborate the facts where relevant; they are not universally required documents.

For an agent or software issue, preserve instructions, submissions, messages and logs. Explain the taxpayer's own arrangements and steps after discovering the problem. Do not assert that delegation or a provider fault automatically transfers responsibility or establishes an excuse. HMRC assesses the actual facts and statutory ground.

A direct-tax CT appeal first goes to HMRC. If it is not settled, HMRC may offer an independent internal review or the taxpayer may take the appeal to the First-tier Tribunal. For VAT, the decision letter generally offers the choice of accepting an HMRC review or appealing directly to the Tribunal. A review is carried out by an HMRC officer not previously involved, and the review conclusion has its own Tribunal time limit. Check the letter and official instructions; this guide does not cover litigation strategy.

HMRC says a penalty under appeal or review generally need not be paid until resolved. Do not infer that the tax itself, any late-payment interest, or every collection action is suspended. HMRC has separate rules for postponing disputed direct tax and for VAT tax payment/hardship at Tribunal. Confirm the account position rather than withholding an unrelated amount on the strength of a penalty appeal.

Stop and use the notice-specific official route if the charge concerns PAYE, Self Assessment, an inaccuracy, a failure to notify, an information notice, an old VAT default surcharge, a tax assessment or interest. Those subjects can differ in appeal right, ground, deadline, required form or review choice. This page does not make their procedures interchangeable.

An HMRC appeal generator is not offered. It could not determine the penalty regime, legal ground, deadline or evidence sufficiency from free text. This guide explains how to locate the applicable official process; it does not draft, submit, score or predict an appeal. For disputed statutory interpretation, collection or Tribunal questions, obtain case-specific professional advice.