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HMRC internal manual

Compliance Handbook

Offshore matters: asset-based penalties: appeal rights and processes

A person may appeal against HMRC’s decision that an asset-based penalty is payable by that person.

A person may also appeal against the amount of the asset-based penalty.

An appeal for the purposes of this schedule is to be treated in the same way as an appeal against an assessment to the tax concerned. For further information on the treatment of appeals, see the Appeals, Reviews and Tribunals Guidance.

A person is not required to pay a penalty before an appeal against the assessment of the penalty is determined.

FA 2016/Sch 22/Paras 16 and 17