Income Tax Act 2007 section 257EE

Appeal against refusal to authorise compliance certificate

Section 257EE provides a route of appeal for a company whose application for a compliance certificate has been refused by HMRC.

  • If HMRC refuse to authorise the issue of a compliance certificate, the company can appeal that decision.
  • The refusal is legally treated as if HMRC had disallowed a claim made by the issuing company.
  • This treatment brings the refusal within the existing appeals framework set out in the Taxes Management Act 1970.
  • The company therefore has access to the same appeal rights and procedures as for any other disallowed tax claim.

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