How to Appeal a Gross Payment Status Refusal (Step-by-Step)

May 5, 2025 | Blog

Here’s exactly what you need to do if HMRC has refused your gross payment status:

Step 1: Understand HMRC’s Reason for Refusal

Carefully read the HMRC letter explaining why your application was denied. Common reasons cited might be:

  • Late filings or payments

  • Incorrect or incomplete records

  • Past compliance issues

You need to clearly understand HMRC’s grounds before you appeal.


Step 2: Gather Your Evidence

You’ll need solid evidence to challenge HMRC’s decision. Good evidence might include:

  • Proof of timely returns (CIS, VAT, PAYE)

  • Bank statements or HMRC payment records showing payments were made on time

  • Evidence any previous compliance issues have been resolved

  • Supporting documentation showing your business meets turnover requirements

The more comprehensive your evidence, the better.


Step 3: Prepare Your Appeal Letter

Your appeal should clearly set out:

  • Your business details (name, UTR, CIS registration)

  • Reference the original HMRC refusal letter clearly

  • Explain specifically why you disagree with HMRC’s decision

  • Clearly summarise your supporting evidence

Always remain factual, professional, and clear—avoid emotional language.


Step 4: Submit Your Appeal Promptly

You must submit your appeal within 30 days of receiving HMRC’s refusal letter.

Send your appeal clearly and securely to the address HMRC provides (usually indicated on their refusal letter). Keep a dated copy of your appeal letter and proof of postage or electronic submission.


Step 5: Follow Up and Respond Promptly

HMRC may ask for additional documentation or clarification. Respond quickly and clearly to any requests—this shows HMRC you’re organised and proactive.


Step 6: Consider an Independent Tribunal if Needed

If your appeal to HMRC is rejected again, you can take your case to an independent tax tribunal.

Tribunals are independent and impartial—often resulting in successful outcomes for businesses who genuinely meet criteria but faced administrative errors or misinterpretations by HMRC.


🚫 Common Mistakes When Appealing Gross Payment Status Refusals

  • Ignoring or delaying your response (strict deadlines apply!)

  • Poorly organised or unclear evidence

  • Emotional or unprofessional appeals

  • Failing to properly address HMRC’s concerns in detail


📋 Example: Successful Appeal of Gross Payment Status

A construction company client we recently helped had their gross payment application denied due to two mistakenly recorded late VAT payments.

We successfully appealed by clearly providing:

  • Bank records proving payments were made on time

  • A clear timeline explaining the administrative errors

  • Supporting documents demonstrating the company’s strong compliance record

Within four weeks, HMRC reversed their decision, and the company received gross payment status.


📞 Need Help Appealing a Gross Payment Refusal?

At Thomas Emlyn Ltd, we specialise in helping construction businesses successfully appeal gross payment status refusals.

We will:

  • Review your HMRC correspondence and reasons for refusal

  • Prepare a strong, evidence-based appeal letter

  • Handle all communication with HMRC

  • Represent you effectively if a tribunal is required

📞 Book a discovery call and get your gross payment status appeal started.


📌 Final Thoughts

A gross payment status refusal isn’t the end of the road. If you genuinely meet HMRC criteria and can clearly prove compliance, appealing is often successful.

Don’t accept HMRC’s initial refusal without challenging it effectively. The right evidence, clearly presented, makes all the difference.

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