AH2265 - ITSA Appeals: Partnerships: Appeal against a HMRC amendment of a partnership statement


TMA70/S31(1)(b) grants the right of appeal against an amendment made by HMRC on completion of an enquiry into a partnership return. An appeal will normally be made on the grounds that the amendment is incorrect or the actual liability has yet to be determined.

TMA70/S31(1)(c) grants the right of appeal against an amendment of a partnership return under TMA70/S30B(1) (amendment by HMRC where loss of tax discovered).

Such appeals must be made by the nominated partner (or agent).

See the SA Manual for procedural guidance on how to handle an appeal against a HMRC amendment of a partnership statement and other non-charge based items.

Once the partnership statement becomes final, i.e. there has been no appeal within the 30 days allowed or the appeal has been determined either by agreement or by the Commissioners, consequential HMRC amendments are made to each partner’s self assessment to give effect to the changes made to the partnership statement. The partners have no right of appeal against the amendments to their self assessments.