Taxes Management Act 1970 Schedule 1A paragraphs 9–11

Appeals against amendments made following an enquiry into a claim

Section 9–11 of Schedule 1A sets out the rights and procedures for appealing against conclusions, amendments or decisions contained in a closure notice issued by HMRC following an enquiry into a claim not included in a return.

• A taxpayer may appeal against any conclusion, amendment or decision contained in a closure notice, by giving written notice to the HMRC officer who issued it within 30 days
• Where the appeal involves questions of residence, ordinary residence, domicile or certain overseas pension funds, the deadline for lodging the appeal is extended to three months from the date the closure notice was issued
• If the appeal reaches the tribunal, the tribunal has power to vary the amendment — even if the variation is not in the taxpayer's favour — and may adjust the extent to which a claim is allowed or disallowed
• Any variation to an amendment, whether made by HMRC, the tribunal or a court, is subject to the same consequential adjustment provisions that applied to the original amendment