Taxation (International and Other Provisions) Act 2010 section 170

Appeals against transfer pricing notices

Section 170 sets out the right of a person who receives a transfer pricing notice to appeal against the decision to issue that notice, including the permitted grounds and the time limit for doing so.

• A person who receives a transfer pricing notice may appeal, but only on the limited grounds that the relevant qualifying condition for issuing the notice has not been met — either the condition relating to small enterprises under section 167A or the condition relating to medium-sized enterprises under section 168.
• The appeal must be made in writing and addressed to the specific HMRC officer identified in the transfer pricing notice itself, as required by section 169.
• The written notice of appeal must be submitted within 30 days of the date on which the transfer pricing notice was given.
• The appeal right is narrow in scope — it does not allow a general challenge to the notice but is confined to disputing whether the statutory conditions for issuing the notice were actually satisfied.