SolvedCH84070 | Penalties for Inaccuracies: Appeals against a penalty: Which Tribunal will hear the appeal and procedures
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 CH81011 for full details.
All appeals will be to the First-tier Tribunal.
An appeal will be treated for procedural purposes in the same way as an appeal against an assessment to the tax concerned. This will not apply where the legislation expressly provides for an alternative approach.
However, this does not extend to any procedural requirement regarding payment of the tax due. A person who wants to appeal against an inaccuracy penalty under Schedule 24 FA07 is not required to pay the underlying tax or the penalty before their appeal can be heard.
You can find further guidance on the review and appeal procedure in the Appeals, Reviews andTribunals Guide (ARTG).