Finance Act 2021

Further provision about appeals

11 (1) An appeal relating to a decision that an amount is due from a person may not be considered by the appeal tribunal unless the amount which HMRC have determined to be due has been paid or deposited with HMRC.

(2) But sub-paragraph (1) does not apply if—

(a) HMRC are satisfied or, if HMRC are not satisfied but the appeal tribunal have decided, on the application of the appellant, that the requirement to pay or deposit the amount would cause the appellant to suffer hardship, and

(b) the appellant has paid or deposited such other amount (if any) by way of security as HMRC or, as the case may be, the appeal tribunal consider appropriate.

(3) Notwithstanding the provisions of sections 11 and 13 of the Tribunals, Courts and Enforcement Act 2007, the decision of the appeal tribunal as to the issue of hardship is final.