Is it possible to appeal Sect 28c determination out of time?

Is it possible to appeal Sect 28c determination...

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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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By Paul Soper
23rd Jul 2013 19:32

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

 

 

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