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HMRC internal manual

Securities Guidance

Introduction and the law: the law on security: Climate Change Levy: person’s right to appeal to an independent tribunal

Paragraph 121 of Schedule 6 to the Finance Act 2000 provides

121(1) Subject to paragraph 122, an appeal shall lie to an appeal tribunal from any person who is or will be affected by any decision of HMRC with respect to any of the following matters-

121(1)(f) the imposition of a requirement on any person to give security, or further security, under paragraph 139 and the amount and manner of providing any security required under that paragraph.

The person is not required to lodge the security with the court or with us before the tribunal may hear their appeal.