'HMRC's Reviews and Appeals - 2013-14' contains statistics showing the outcome of reviews and appeals against HMRC tax decisions for the year 1 April 2013 to 31 March 2014. It covers both internal reviews and appeals resolved with or without a Tribunal hearing.

The statistics are, of course, presented in a way which highlights HMRC's successes, such as the fact that three-quarters of decisions made by the Tribunal in 2013/14 were in HMRC's favour. However, presenting the data in another way is instructive:

  1. Of the 38,621 HMRC decisions reviewed in 2013/14, 49 percent were either varied or cancelled;
  2. 44% of the 4,076 appeals concluded before a Tribunal hearing were decided in the taxpayer's favour; and
  3. 607 of the 2,550 appeals that did proceed to a Tribunal hearing were decided wholly or partly in the taxpayer's favour.

These statistics are best demonstrated by a simple table:

Click here to view the table.

In total, therefore, HMRC made 21,235 mistaken "decisions" in 2013/14, which amounts to almost half of all cases reviewed or appealed. This is a remarkable statistic, particularly noting that the original decisions would have been made by HMRC following lengthy interaction with the taxpayer and internal review within HMRC.

The data suggests that if you think HMRC is wrong there is a significant chance that they may be!