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HMRC internal manual

Compliance Handbook

Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: appeals against the penalty

A person can appeal against

  • the imposition of a penalty, or
  • the amount of the penalty.

If the appeal cannot be settled by agreement then the person may notify their appeal to the tribunal. Appeals will usually be heard by the First-tier Tribunal. The tribunal

  • may affirm or cancel HMRC’s decision to charge a penalty, or
  • may affirm the amount of the penalty, or
  • substitute it with another decision that HMRC had the power to make.

A customer may still ask for an independent review of HMRC’s decision at any time after they have appealed but before the appeal has been settled.

The Appeals, Reviews and Tribunals Guidance (ARTG) contains full guidance on the review and appeals process.