Taxation (International and Other Provisions) Act 2010 section 52

Appeal against closure notice or notice under paragraph 51

Section 52 of Schedule 7A sets out a company's right to appeal against certain HMRC notices issued during the transfer pricing enquiry process, and the time limit for doing so.

• A company may appeal against a statement included in a closure notice that adjusts its tax position in relation to transfer pricing.
• A company may also appeal against a separate notice issued by HMRC under paragraph 51, which amends the company's position outside of a formal enquiry.
• Any appeal must be made within 30 days of the date the notice was given to the company.
• The appeal must be sent to the specific HMRC officer who issued the notice being challenged.