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HMRC internal manual

Compliance Handbook

Data gathering: Appeals against data-holder notices: Overview

Any person to whom a data-holder notice is addressed may appeal against the notice, or any requirement in the notice, subject to two exceptions.

The first exception is that the data-holder cannot appeal against the requirement to provide relevant data that forms part of their statutory records.

The second exception is that the data-holder cannot appeal where the tribunal has approved the notice.

On an appeal referred to the tribunal, the tribunal has wide powers to vary a requirement in a notice and to set a new deadline to comply. A decision by the tribunal is final.