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HMRC internal manual

Securities Guidance

Introduction and the law: the law on security: Insurance Premium Tax: registrable person’s right to appeal to an independent tribunal

Section 59 of the Finance Act 1994 provides

59(1) Subject to section 60, 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-

(i) the requirement of any security under paragraph 24 of Schedule 7 to this act or its amount.

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