Section 170 | Appeals against transfer pricing notices

(1)A person to whom a transfer pricing notice is given may appeal against the decision to give the notice, but only on one of the following grounds—

(za)in the case of a transfer pricing notice given under section 148A(3), that the condition in section 148A(1)(c) is not met,

(zb)in the case of a transfer pricing notice given under section 164A(8), that there would be no loss of tax resulting from—

(i)in the case of a notice under section 164A(8)(a), the application of section 164A(1) in relation to the chargeable period and provision to which the notice relates, or

(ii)in the case of a notice under section 164A(8)(b), the application of section 164A(1) in relation to that period and any qualifying UK to UK provision for which the person is the potentially advantaged person, or

(a)that the condition in section 167A(1)(b) is not met, or

(b)that the condition in section 168(1)(a) is not met.

(1A)A person to whom a transfer pricing notice is given under section 148A(3) may appeal against a decision of the Commissioners for His Majesty's Revenue and Customs to consider the case to which the notice relates analogous to a case that would meet the participation condition only as a result of section 161 (actual provision relates, to any extent, to financing arrangements).

(2)An appeal under this section must be brought by giving written notice of appeal to the officer of Revenue and Customs identified in the notice in accordance with section 169(4).

(3)The notice of appeal must be given before the end of the period of 30 days beginning with the day on which the transfer pricing notice is given.