Notice of appeal
36(1)Notice of an appeal under paragraph 35 must be given—
(a)in writing,
(b)within 30 days after the specified date,
(c)to HMRC.
(2)In sub-paragraph (1) “specified date” means—
(a)in relation to an appeal under paragraph 35(1)(a), the date on which the notice of amendment was issued;
(b)in relation to an appeal under paragraph 35(1)(b), the date on which the closure notice was issued;
(c)in relation to an appeal under paragraph 35(1)(c) the date on which the HMRC determination was issued;
(d)in relation to an appeal under paragraph 35(1)(d) or (e), the date on which the notice of assessment was issued.
(3)The notice of appeal must specify the grounds of appeal.
(4)Where a determination has been made under paragraph 18 as to the amount of tax to which a person is chargeable with respect to a single-dwelling interest, the only grounds on which an appeal lies under paragraph 35(1)(c) are—
(a)that the condition in section 94(2)(a) (nature and value of interest) is not met in relation to the interest in question on any day to which the determination relates,
(b)that the person, partnership or scheme that the determination identifies as meeting the ownership condition on one or more days does not meet that condition on any day in the chargeable period,
(c)if the tax is determined to be chargeable by virtue of section 94(5), that a person identified in the determination as one of the responsible partners is not a responsible partner in relation to any tax chargeable for the period in question, or
(d)if the tax is determined to be chargeable by virtue of section 94(6), that the person identified in the determination as the chargeable person in relation to the collective investment scheme concerned is not the chargeable person.