The provisions dealing with the right to appeal can be found in FA 2008, Sch. 36, para. 29-31.
The person receiving an information notice can appeal against the notice or against a requirement in it.
As well as a failure to follow the rules specifically relating to a particular type of notice, the grounds for appeal can include a failure to either:-
Where the appeal is against the notice, the person does not have to comply with it until the appeal has been heard. But where the appeal is against a requirement in the notice, the person must comply with the other requirements.
If the notice has been issued with the approval of the Tribunal the only way to challenge it is by way of judicial review.
An appeal must:-
If it is not settled by agreement between the appellant and HMRC it will be heard by the Tribunal, which can:-
The Tribunal’s decision is final – there is no further right of appeal.
If the Tribunal confirms or varies the notice, the person must comply within the period set by the Tribunal. If the Tribunal does not set a period, the person must comply within the period set by the officer.