22(1) This rule applies where an enactment provides, in any terms, that an appeal may not proceed if the liability to pay the amount in dispute is outstanding unless HMRC or the Tribunal consent to the appeal proceeding.

22(2) When starting proceedings, the appellant must include or provide the following in or with the notice of appeal–

(a)a statement as to whether the appellant has paid the amount in dispute;

(b)if the appellant has not paid the amount in dispute, a statement as to the status or outcome of any application to HMRC for consent to the appeal proceeding; and

(c)if HMRC have refused such an application, an application to the Tribunal for consent to the appeal proceeding.

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