Taxation (International and Other Provisions) Act 2010 section 75

Notice of appeal

Section 75 sets out the requirement for how a notice of appeal must be made under the transfer pricing documentation provisions of Schedule 7A.

• Any appeal made under Schedule 7A must be submitted by way of a formal notice of appeal.
• The notice of appeal must specify the grounds on which the appeal is being made.
• It is not sufficient simply to state that an appeal is being made — the reasons must be clearly set out.
• This requirement ensures that HMRC and any tribunal can understand the basis of the taxpayer's challenge from the outset.