The person to whom a third party is issued with the agreement of a named taxpayer can appeal against the notice or any requirement in it. The only grounds of appeal are that complying with the notice would be unreasonably burdensome (Finance Act 2008, Sch. 36, para. 30).

There is no right of appeal, however, against:-

  • A requirement to provide information or produce a document that forms part of the taxpayer’s statutory records
  • A notice issued with the approval of the Tribunal
  • A notice requiring only information or documents that form part of the taxpayer’s statutory records and relate to:-


  • The supply of goods or services
  • Acquisitions of goods from another member state
  • Importation of goods from outside the member states in the course of carrying on a business.


See FA 2008, Sch. 36, para. 29 (2) and (3) and para. 34.

For more information on how to appeal against a notice from HMRC, call KinsellaTax on 0800 471 4546


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