Section 170 | Appeal against a decision to issue a promoter action notice

(1)A recipient of a promoter action notice may appeal to the tribunal against a decision to issue the notice on the grounds that—

(a)the recipient is not providing the goods or services specified in the notice to the target identified in the notice;

(b)the goods or services are not being used wholly or partly in connection with the arrangements referred to in section 167(1).

(2)Notice of an appeal must—

(a)state the ground of appeal, and

(b)be given in writing to HMRC before the end of the period of 30 days beginning with the day on which the promoter action notice was issued.

(3)The provisions of Part 5 of TMA 1970 relating to appeals have effect in relation to appeals under this section as they have effect in relation to an appeal against an assessment to income tax.

(4)In this section, the “tribunal” means the First-tier Tribunal or, where determined by or under the Tribunal Procedure Rules, the Upper Tribunal.