In my view, the statutory review letter tends to be regurgitation of the caseworker’s view. I have only had one statutory review reverse the decision and another downgrade the deliberate and concealed penalty to deliberate.I was surprised to see in the HMRC Annual report 2020 that 45% of the original decisions are cancelled, a further 11.4 % decisions are varied. Only 43% of the statutory review upholds the original decision. I maybe doing an injustice to the Statutory Review process? It would be good to see your views in the comments. Less than 1% of my cases have had a successful statutory review, but more than 99% of my tax cases have had a successful resolution where the tax liability has been reduced. It could be because I am dealing with the more difficult tax disputes that the statutory review results are distorted compared to HMRC’s?
Poll: Do you use the HMRC Statutory Review process?