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HMRC internal manual

International Exchange of Information Manual

Notification requirement: Penalties for failure to send notification: Right of appeal

Notification Regulations: Penalties for not sending a notification: Right of appeal

The Financial Institution or Relevant Person may also appeal to the tribunal on the grounds:

  • That there is a reasonable excuse; or
  • That the liability to the penalty does not arise for some other reason.


Notice of an appeal must be given in writing to HMRC, stating the grounds of the appeal.  It must be given before the end of the period of 30 days beginning with the date on which penalty notification was given.