949I Notice of appeal

Summary

A taxpayer shall make an appeal by way of a written notice to the Appeal Commissioners. A notice of appeal is to contain specified particulars such as the taxpayer’s name and address, tax reference number, the decision being appealed, the grounds for the appeal and any other particulars required by the Appeal Commissioners. A taxpayer is required to send a copy of the notice of appeal to Revenue.

It is important to include comprehensive grounds for an appeal in the notice of appeal as the Appeal Commissioners have the discretion, at a later stage in proceedings, not to allow an appellant to rely on grounds that were not included.

Details

(1) An appeal shall be made by way of a written notice to the Appeal Commissioners.

(2) A notice of appeal shall contain:

• the appellant’s name and address,
• the appellant’s relevant tax reference number,
• the appealable matter,
• the grounds of the appeal in detail, and
• any other particulars the Appeal Commissioners may require.

(3) An appellant is also required to state in the notice of appeal whether any conditions necessary for the making of an appeal have been satisfied.

(4) Where an appeal is late, the notice of appeal shall state why the appeal was not made on time.

(5) The appellant must append a copy of the notice provided by Revenue in respect of an appealable matter (e.g. a notice of assessment) to the notice of appeal.

(6) An appellant may not rely on any grounds of appeal not stated in a notice of appeal unless the Appeal Commissioners are satisfied that there was a good reason for not stating those grounds.

Relevant Date: Finance Act 2021