214 Appeal against a section 208 penalty

214  Appeal against a section 208 penalty

(1)     P may appeal against a decision of HMRC that a penalty is payable by P under section 208.

(2)     P may appeal against a decision of HMRC as to the amount of a penalty payable by P under section 208.

(3)     The grounds on which an appeal under subsection (1) may be made include in particular—

(a)     that Condition A, B or D in section 204 was not met in relation to the follower notice,

(b)     that the judicial ruling specified in the notice is not one which is relevant to the chosen arrangements,

(c)

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