INTM620440 - Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Appeals

ITTOIA05/Ch2A/S608Q

This section concerns appeals made against a notice issued under section 608O. For appeals against assessments to tax charged under section 608A, see INTM620530.

Grounds for appeal

A person issued with a notice under section 608O may appeal against the notice but only on the grounds that they do not fall within the definition of relevant person (as defined in section 608O, see INTM620410). Any appeal must be made within thirty days from the date on which the notice was issued.

A person who appeals against a notice may apply for the payment of tax to be postponed under section 55 TMA 1970 until the appeal is settled. See ARTG2510 for further details.

Payment of tax where there is a further appeal

Where there is a further appeal against a determination of the court or tribunal, HMRC may apply to the court or tribunal to hold on to any tax pending the outcome of the further appeal. The court or tribunal may accept the application if it considers that it is necessary for the protection of the revenue.