Appeal to the Tax Chamber of the First-tier Tribunal
When a notice of counteraction has been issued to a taxpayer, they have the right to appeal to the Tax Chamber of the First-tier Tribunal by giving notice to an HMRC officer within 30 days. The appeal may be on the grounds that the transactions in securities legislation does not apply to them in respect of the transaction or transactions in question or that the proposed adjustments are inappropriate1.
The procedure as regards an appeal is in general similar to that for any other tax appeal to the First-tier Tribunal2, but if the appeal is on the grounds that CTA 2010, Pt 15 or ITA 2007, ss 682–713 (Pt 13, Ch 1) does not apply, the onus is on HMRC to establish the circumstance on which they rely3. In practice, before the hearing of an appeal, HMRC may be
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Web page updated on 24 Aug 2024 13:55