SolvedCH123650 | Offshore matters: requirement to correct certain offshore tax non-compliance: failure to correct - penalty assessments - appeals
From HM Revenue & Customs · Compliance Handbook
You must check the date from which these rules apply for the tax or duty you are dealing with. See CH123050 for full details.
A person
may appeal against HMRC’s decision that a failure to correct penalty is due,
may also appeal the amount of the penalty payable,
is not required to pay a penalty before an appeal against the assessment of the penalty is determined.
An appeal for the purposes of this schedule is to be treated in the same way as an appeal against an assessment to the tax concerned. For further information on the treatment of direct tax appeals, see ARTG2100+.