In normal circumstances the penalty is assessed on a person and
any appeal rights are restricted to that person.
In the case of a partnership it is the nature of the
incorrect document that dictates who may appeal. Where the document
is a partnership return made under TMA70/S12AA, the right of appeal
is restricted to the nominated partner or his successor. For other
documents, any partner may appeal on behalf of the partnership.
Where a penalty is payable by a company for a deliberate
inaccuracy which was attributable to an officer of the company, and
we pursue the officer for a portion of the penalty, that officer
will have the same appeal rights as a person would have in respect
of that portion, see
CH84600 for more details.
Appeals may be made by agents on behalf of their
clients.
