ATCS06700 - Governance and legal: appealing a decision
There is no right of appeal or guaranteed entry to the Advance Tax Certainty Service. If the customer believes that HMRC has misunderstood the scope of the application or failed to consider a material fact resulting in determining the eligibility of a clearance request, the customer can contact the Advance Tax Certainty Service within 10 working daysof receiving this e-mail to make representations.
If the customer disagrees with HMRC’s view, they will still be able to take a contrary position in a tax return at a future date, however an enquiry should be anticipated.