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Chapter CH24380

Document Cited in Related
Vincent
Published date11 March 2016
Record NumberCH24380

A person who has received a third party notice may appeal to the tribunal against

  • the notice, or
  • any requirement in the notice

on the grounds that it would be unduly onerous to comply with either the notice or the requirement.

However, there is no right of appeal against

  • a notice (or any requirement in the notice) that has been approved by the tribunal. Any challenge to a tribunal approved notice would be through an application for judicial review, or

  • a requirement in a notice to provide any information, or produce any document, which forms part of the named person’s statutory records, see CH21700. The named person for these purposes means the person whose tax position is being checked and includes

    • a parent undertaking and all its subsidiary undertakings where the notice is given to any person for the purpose of checking the tax position of the parent and one or more subsidiary undertakings, see CH23760, and
    • each partner in a partnership, where the notice is given to any person other than a partner for the purpose of checking the tax position of one or more partners in their capacity as partners in their capacity as such, see CH23680, or

  • a notice (or any requirement in the notice) that refers only to any person’s...

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