Part 13

Tax avoidance
Chapter 1

Transactions in securities

Appeals

Appeals against counteraction notices
705
1
A person on whom a counteraction notice has been served may appeal to the Special Commissioners on the grounds that—
a
section 684 (person liable to counteraction of income tax advantage) does not apply to the person in respect of the transaction or transactions in question, or
b
the adjustments directed to be made are inappropriate.
2
Such an appeal may be made only by giving notice to the Commissioners for Her Majesty’s Revenue and Customs within 30 days of the service of the counteraction notice.
3
On an appeal under this section the Special Commissioners may—
a
affirm, vary or cancel the counteraction notice, or
b
affirm, vary or quash an assessment made in accordance with the notice.
4
But the bringing of an appeal under this section (or a request for its rehearing under section 706) does not affect—
a
the validity of the counteraction notice, or
b
the validity of any other thing done under or in accordance with section 698 (counteraction notices),
pending the determination of the proceedings.