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HMRC internal manual

Offshore Funds Manual

Reporting funds: breaches of reporting fund conditions: consequences of breaches: appeals against exclusion from reporting fund regime - Regulation 115

If HMRC issue an exclusion notice to a reporting fund under regulation 114 (see OFM29320), the fund can appeal against that notice.

Any appeal must be given to HMRC within a period of 42 days, beginning with the day on which the exclusion notice is 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 notice.