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HMRC internal manual

Securities Guidance

Introduction and the law: the law on security: Value Added Tax: taxable person’s right to appeal to an independent tribunal

Under the provisions of section 83(l) of the Value Added Tax Act 1994 a taxable person may appeal to an independent tribunal against a requirement to give security.

83 Subject to section 84, an appeal shall lie to a tribunal with respect of any of the following matters -

(l) the requirement of any security under section 48(7) or paragraph 4(1A) or (2) of Schedule 11.