V5.365 Appeal

A right of appeal is given in respect of1

  1.  

    (1)     the amount of any interest specified in an assessment; and

  2.  

    (2)     the making of an assessment under the extended time limits.

A tribunal has no power to vary an amount assessed by way of interest except in so far as it is necessary to reduce it to the amount which is appropriate in accordance with the legislation2. There is no “reasonable excuse” defence against an assessment to interest3.

No appeal lies against HMRC's decision to exercise their discretion to assess default interest4. The jurisdiction of the tribunal in relation to

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