16(1)An appeal to the Special Commissioners—
(a)against such a determination as is referred to in paragraph 15(3) above, or
(b)against a notification under paragraph 15(4) above,
may be made by the offshore fund or by a trustee or officer thereof on behalf of the fund, and shall be so made by notice specifying the grounds of appeal and given to the Board within 90 days of the date of the notice under paragraph 15(3) or (4), as the case may be.
(2)The jurisdiction of the Special Commissioners on an appeal under this paragraph shall include jurisdiction to review any decision of the Board which is relevant to a ground of the appeal.