The recipient of a notice under FA 2008, Sch. 36, para. 1, a first party notice, is entitled to appeal against the notice or any requirement in it (para. 29(1)) Appeal against the notice is to the First-tier tribunal. However, where HMRC have obtained the consent of the tribunal to the issuing of the notice, there is no right of appeal (para. 29(3)). Additionally, a taxpayer cannot appeal against a notice to provide statutory records (para. 29(2)).

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