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HMRC internal manual

Offshore Funds Manual

From
HM Revenue & Customs
Updated
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Reporting funds: application for reporting fund status: rejection of application - appeals - Regulation 56

If HMRC rejects an application, the person who made the application can appeal by giving notice of appeal to HMRC within a period of 42 days beginning with the day on which a notice rejecting the application was given.

Appeals will be heard by the First-tier Tribunal (or the Upper Tribunal if so determined by Tribunal procedure rules) who may either uphold or quash the rejection of the application. If the tribunal quashes the rejection of the application, the fund will be treated as a reporting fund as if HMRC had accepted the application in the form in which it was considered by the tribunal.