Income Tax Act 2007 section 706

Rehearing by tribunal of appeal against counteraction notice

Section 706 deals with what happens when a tribunal rehears an appeal against a counteraction notice issued by HMRC, including the powers available to the tribunal during such a rehearing.

  • When a taxpayer appeals against a counteraction notice, the tribunal conducts a full rehearing of the case rather than simply reviewing the original decision.
  • The rehearing is handled by an officer of Revenue and Customs (the officer dealing with the case), replacing the previous references to "the Board" in older legislation.
  • The tribunal has the same powers during the rehearing as were previously available to the Special Commissioners when they dealt with such appeals.
  • The tribunal's powers are stated simply as being equivalent to those of the Special Commissioners, without the older legislation's redundant distinction between "powers" and "authorities".

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