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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information Notices: Appeals: Appealing against a taxpayer notice

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

  • the notice, or
  • any requirement within the notice

except that there is no right of appeal against

  • a notice (or any requirement in the notice) that has been approved by the tribunal, see CH24120. The tribunal’s decision to approve a notice or not is final. 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 person’s statutory records, CH21700, or
  • a notice (or any requirement in the notice) that refers to any person’s statutory records relating only to

    • the supply of goods or services or
    • the acquisition of goods from another EU member state or
    • the importation of goods from outside the EU in the course of carrying on a business.

See CH21700 for guidance on resolving disputes about whether a document is or is not a statutory record. See the Appeals, Review & Tribunals Guidance (ARTG) for full guidance on the appeal and review procedure.