Corporation Tax Act 2010 section 546

Appeal against notice under section 545

Section 546 provides the right of a UK REIT company (or a member of a UK REIT group, including a joint venture company) to appeal against a notice issued by HMRC to cancel a tax advantage under section 545.

• A company that receives a section 545 notice cancelling a tax advantage may appeal against that notice.
• The appeal must be made in writing to an officer of HMRC within 30 days of the date the section 545 notice was issued.
• If the appeal is referred to the tax tribunal, the tribunal may quash, affirm or vary the notice.
• The tribunal therefore has full discretion to cancel the notice entirely, uphold it as issued, or modify its terms.