CIS Subcontractor Client has submitted 2005/06, 2006/07, & 2007/2008 returns to HMRC following repeated requests for same. Now been told that out of time to be amended. Section 28C Determination previously issued and now not being amended. Can this be appealed against?
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No appeal I'm afraid
This was considered in 2012 by the FTT who concluded that there is no right of appeal - http://www.bailii.org/uk/cases/UKUT/TCC/2012/184.html
Your only recourse is to seek special relief (the new "improved" version of equitable liability) - http://www.hmrc.gov.uk/manuals/sacmanual/SACM12230.htm