SolvedUTT17500 | Penalties: Uncertain Tax Treatment appeals
From HM Revenue & Customs · Uncertain Tax Treatments by Large Businesses Manual
The Uncertain Tax Treatments (UTT) appeals follows that of the direct taxes guidance on the appeals and reviews process, which is contained in the Appeals Reviews and Tribunals Guidance (ARTG2010 and ARTG2100+ respectively).
An appeal may be made by the persons listed in ARTG2150, as for all other direct tax appeals if there is a reasonable excuse for not making the return by the deadline. There is comprehensive guidance regarding reasonable excuse at CH160000.
If you have any questions or comments regarding the draft guidance, please contact Uncertain tax treatment consultation team.