Schedules
Schedule 14Administration of multinational top-up tax
Part 12Appeals and claims
55Appeals of decisions: general
1
An appeal may be brought against—
a
an amendment of a self-assessment return under paragraph 19 (amendment during enquiry to prevent loss of tax);
b
an amendment made by a closure notice under paragraph 22;
c
a discovery assessment;
d
an assessment of a penalty under paragraph 42, 43 or 46;
e
an amendment made by a closure notice under paragraph 53;
f
an assessment made under paragraph 54.
2
Any such appeal is to be brought by the filing member (“the appellant”).
3
Notice of the appeal must be given to HMRC—
a
in writing, and
b
within 30 days after the specified date.
4
“Specified date” means—
a
in relation to an appeal under sub-paragraph (1)(a), the date on which the notice of amendment was issued;
b
in relation to an appeal under sub-paragraph (1)(b) or (e), the date on which the closure notice was issued;
c
in relation to an appeal under sub-paragraph (1)(c), (d) or (f), the date on which the notice of assessment was issued.
5
The notice of appeal must specify the grounds of appeal.
6
Notice may be given after the time limit in sub-paragraph (3)(b) if—
a
HMRC agrees, or
b
where HMRC does not agree, the tribunal gives permission.
7
HMRC must agree to notice being given after the time limit if the appellant has requested in writing that HMRC do so and HMRC is satisfied—
a
that there was a reasonable excuse for not giving the notice before the time limit, and
b
that the request has been made without unreasonable delay.
8
If a request of the kind mentioned in sub-paragraph (7) is made, HMRC must notify the appellant of whether or not HMRC agrees to the request.