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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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HM Revenue & Customs
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Schedule 4 Company Share Option Plan (CSOP): Notification & Enquiries: Appeals

A company may appeal against:

  • HMRCs decision to issue a closure notice in relation to a “serious” or “less serious” error (see ETASSUM46150);
  • HMRCs decision to specify or not specify a date upon which tax advantaged status is withdrawn in relation to a “serious” or “less serious” error (see ETASSUM46150); and
  • The amount of any penalty payable.

An appeal must be made within 30 days of the closure notice, default notice or notice of assessment of the penalty. Appeals should be made in writing to the Employee Shares & Securities Team -

Post: Room G47, 100 Parliament Street, London, SW1A 2BQ

E-mail: Shareschemes mailto:

Where an appeal in relation to a decision is notified to a Tribunal, the Tribunal may affirm or cancel the decision. The Tribunal may also substitute another decision in relation to an appeal made in relation to paragraphs 28K(2) (a decision that the requirements of parts 2-6 of Schedule 4 are not met or have not been met and that the situation is either “serious” or “less serious” or a decision to specify or not specify a relevant time for the closure notice) and 28K(3)(b) (a decision to specify or not specify a date upon which tax advantaged status is withdrawn in relation to a default notice) – (see ETASSUM46120). Where an appeal in relation to the amount of a penalty is notified to a Tribunal, the Tribunal may affirm the amount of the penalty or substitute the amount with another amount.