Corporation Tax Act 2010 section 750

Appeals against counteraction notices

Section 750 sets out the right of a company to appeal against a counteraction notice issued by HMRC, including the grounds for appeal, the time limit, the powers of the tribunal, and the continuing validity of the notice while the appeal is pending.

• A company may appeal on the grounds that section 733 does not apply to its transaction(s), or that the adjustments directed are inappropriate.
• The appeal must be made by giving notice to HMRC within 30 days of receiving the counteraction notice.
• The tribunal may affirm, vary or cancel the counteraction notice, or affirm, vary or quash any related assessment.
• Filing an appeal does not suspend the validity of the counteraction notice or any action taken under section 746 while the appeal is being determined.