This page covers appeals against Revenue Jersey determinations, customs disputes, and decisions by the Comptroller.
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Tax and Customs Appeals Under Jersey Law
Appeals under the Income Tax (Jersey) Law 1961 and customs law have strict deadlines. A late appeal is accepted only where absence, sickness or another reasonable cause prevented you from appealing in time.
A dispute can move from the Comptroller to the Commissioners of Appeal and then to the Royal Court of Jersey.
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Which decisions can be appealed, and where
The route depends on the tax. Income tax assessments are appealed under the Income Tax (Jersey) Law 1961, GST decisions under Part 16 of the Goods and Services Tax (Jersey) Law 2007, and customs decisions through a separate review run by Jersey Customs and Immigration Service under the Customs and Excise (Jersey) Law 1999.
Income tax and GST disputes that do not settle go to the Commissioners of Appeal for Taxes. They are established by the Revenue Administration (Jersey) Law 2019 and appointed by the Minister for Treasury and Resources. According to gov.je, Commissioners must be Jersey residents with financial experience and do not need to be legally qualified.
An income tax appeal, step by step
- Appeal in writing within 40 days. Revenue Jersey's appeal guidance says your appeal must be made within 40 days of the date of issue of the notice of assessment. It must give your reasons, the amount of tax you believe is due and any supporting evidence.
- Pay the tax you accept. The same guidance says the amount you believe is due must be paid, and a 10% surcharge applies to underpaid tax not paid by the deadline.
- Late appeals. A late appeal is accepted only where absence, sickness or another reasonable cause prevented you from appealing in time, and you then appealed without unreasonable delay.
- Settlement or internal review. Many appeals end in a written agreement with the Comptroller of Revenue. The guidance allows a further 40 days to revoke that agreement. You can also ask for an internal case review by an officer who was not involved in the decision.
- Hearing before the Commissioners. If the dispute is not settled, it is heard by the Commissioners. Since 2024, if you have appealed in writing to the Comptroller and have not been notified of a hearing, you can give notice directly to the Commissioners (gov.je).
- Royal Court. A party who disputes the Commissioners' decision must give notice to the Royal Court of an intention to appeal within 21 days, setting out the grounds.
What the Commissioners can and cannot do
The Commissioners decide questions of fact and law in private hearings. They can confirm or amend an assessment, summon and examine witnesses, obtain expert advice and publish their determination. They cannot change the law itself.
Two points often surprise appellants:
- The Commissioners have no power to award costs in any circumstances (gov.je), so winning does not recover what you spent.
- Revenue Jersey also brings delay cases where a taxpayer has appealed but has not sent in the returns or accounts needed to show the assessment is wrong.
You can present your own case or be represented by an advocate, solicitor or accountant.
GST and penalty appeals
GST appeals have their own conditions. Revenue Jersey's GST appeals page says an appeal must be made within 40 days of the decision, or within 40 days of a review report if you first asked for an internal review. Reviews are decided within 20 working days.
Appealable GST decisions include registration, input tax credits, refund claims, penalties and assessments. Before the Commissioners will hear a GST appeal, you must be up to date with returns, have paid undisputed amounts and have deposited the disputed sum with the Comptroller.
Some penalty notices issued under the Revenue Administration (Jersey) Law 2019 carry their own right of appeal. Article 14 allows an appeal to the Commissioners within 40 days of service of the notice.
Customs decisions take a different route
Customs disputes do not start with the Commissioners. Under the customs appeals guidance, you can appeal decisions that impose a restriction, prohibition or requirement under the Customs and Excise (Jersey) Law 1999, and decisions affecting your liability to duty or your eligibility for relief or repayment.
- The appeal must be made within 30 days of the decision.
- Include the consignment number, an outline of the decision, the amount at stake and which legislation you say was misapplied.
- An officer reviews the decision and the outcome is given within 30 days.
- You then have one month to appeal that outcome. The route depends on the type of decision, and the guidance names the States of Jersey Complaints Board as a further option.
What to gather before speaking to an advocate
- The notice of assessment or decision, with its date of issue, so the deadline can be checked
- Your return, accounts and any working papers behind the figures in dispute
- All correspondence with Revenue Jersey or Customs, including any settlement offer
- Your own figure for the tax you accept is due, and proof of payment
- For customs: the consignment number, invoices and any supplier or specialist evidence
Tax & Customs Appeals Asked Questions
What are the strict time limits for lodging a Tax or Customs Appeal in Jersey?
For income tax, Revenue Jersey says you must appeal in writing within 40 days of the date of issue of your notice of assessment; a late appeal is accepted only for absence, sickness or another reasonable cause. Customs decisions must be appealed within 30 days of the decision.
What happens if my appeal cannot be resolved with the Comptroller?
If you cannot settle with the Comptroller of Revenue, the appeal is heard by the Commissioners of Appeal for Taxes. A party who disputes their decision must give notice to the Royal Court of an intention to appeal within 21 days.
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