Under TMA70/Sch1A/PARA6A an appeal may be brought against a
notice under TMA70/Sch1A/PARA6(2). Such a notice requires a
claimant to produce documents and to furnish accounts or
information required to determine whether, and if so to what
extent, a claim (or an amendment to a claim) made outside a return
which is the subject of an enquiry is incorrect.
The appeal must be made within 30 days of the date of issue
of the notice (TMA70/Sch1A/PARA6A(2)).
The right of appeal against the notice for documents or
particulars does not provide the taxpayer with the opportunity to
raise an objection to our right to enquire into the claim.
The provisions relating to an enquiry into a claim made
outside a return in TMA70/Sch1A/PARA6A are analogous to those in
TMA70/S19A(6) which relate to an enquiry into return and the
guidance in AH2115 (appeal against a notice under TMA70/S19A)
applies equally to an appeal against a notice under
TMA70/Sch1A/PARA6(2).
