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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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PRT: administration: appeals against claim decisions - appeal to the Upper Tribunal

If a participator or the Board are dissatisfied with the First-tier Tribunal’s decision they may appeal against the decision to the Upper Tribunal (ARTG1010, AM5930 & 5940). On such an appeal effect is to be given to expenditure determined as allowable or as qualifying for supplement as if allowed on the date of appeal and any necessary amending assessment made (OTA75\SCH5\PARA8). Any tax which so becomes payable in an assessment for a chargeable period is to carry interest from 2 months after the end of the period to the date of payment. A matter is not deemed to be finally determined until it can no longer be varied or overruled by any court.