Part 13

Tax avoidance
Chapter 1

Transactions in securities

Appeals

Rehearing by tribunal of appeal against counteraction notice
706
1
The appellant or an officer of Revenue and Customs may, if dissatisfied with the determination of the Special Commissioners under section 705, require the appeal to be reheard by the tribunal appointed under section 704.
2
Such a request may be made only by giving notice to the Clerk to the Special Commissioners within 30 days after the determination.
3
If such a request is made—
a
the Special Commissioners must transmit to the tribunal any document in their possession which was delivered to them for the purposes of the appeal, and
b
the tribunal must rehear and determine the appeal.
4
The tribunal has the same powers in relation to the appeal as the Special Commissioners.
5
On the rehearing of an appeal under this section, the tribunal may—
a
affirm, vary or cancel the counteraction notice, or
b
affirm, vary or quash an assessment made in accordance with the notice.
6
The tribunal’s determination is final and conclusive (but see sections 707 to 711).