Section 705 — Income Tax Act 2007: Appeals against counteraction notices

Appeals against counteraction notices 705 1 A person on whom a counteraction notice has been served may appeal ... on the grounds that—

a section 684 (person liable to counteraction of income tax advantage) does not apply to the person in respect of the transaction or transactions in question, or b the adjustments directed to be made are inappropriate.

2 Such an appeal may be made only by giving notice to the Commissioners for Her Majesty's Revenue and Customs within 30 days of the service of the counteraction notice.

3 On an appeal under this section that is notified to the tribunal, the tribunal may—

a affirm, vary or cancel the counteraction notice, or b affirm, vary or quash an assessment made in accordance with the notice.

4 But the bringing of an appeal under this section ... does not affect—

a the validity of the counteraction notice, or b the validity of any other thing done under or in accordance with section 698 (counteraction notices), pending the determination of the proceedings.