Appeal
24(1)A person may appeal against—
(a)a relief restriction notice, or
(b)a restricted period extension notice.
(2)An appeal under this paragraph must be made within the period of 30 days beginning with the day on which the notice is given.
(3)An appeal under this paragraph is to be treated in the same way as an appeal against an assessment to income tax (including by the application of any provision about bringing the appeal by notice to HMRC, about HMRC’s review of the decision or about determination of the appeal by the First-tier Tribunal or Upper Tribunal).
(4)On an appeal the tribunal may—
(a)cancel HMRC’s decision, or
(b)affirm that decision with or without any modifications in accordance with sub-paragraph (5).
(5)On an appeal the tribunal may rely on paragraph 23 (mitigation of restriction of relief)—
(a)to the same extent as HMRC (which may mean applying the same mitigation as HMRC to a different starting point), or
(b)to a different extent, but only if the tribunal thinks that HMRC’s decision in respect of the application of paragraph 23 was flawed.
(6)In this paragraph “tribunal” means the First-tier Tribunal or Upper Tribunal (as appropriate by virtue of sub-paragraph (3)).