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HMRC internal manual

Tonnage Tax Manual

Tax avoidance: Action by HMRC

Exclusion procedure: Appeals

If HMRC makes a decision to exclude a company or group from tonnage tax because it has been a party to tax avoidance, the company or group may appeal against the exclusion notice within 30 days of the date of issue of the notice.

Where a group is appealing, only one appeal may be brought, but it may be brought jointly by two or more members of the group.

The appeal should be delivered to the officer who issued the notice.

A company that disagrees with HMRC’s decision may appeal to have the decision reviewed internally, or appeal to have the decision heard by the First Tier Tribunal. If the company seeks an internal review, and does not agree with the decision of that review, it may then appeal to the First Tier Tribunal – see FA00/SCH22/PARA43(1).


FA00/SCH22/PARA43 (appeals) TTM17256
Exclusion procedure for tax avoidance TTM05530