# Finance Act 2026, Paragraph 20: Appeals

Extent: E+W+S+N.I.

(1) A person may appeal against a penalty assessment under paragraph 18—
(a) on the grounds that liability to the penalty does not arise, or
(b) as to the amount of the penalty.
(2) Notice of an appeal must—
(a) state the grounds of appeal, and
(b) be given in writing to HMRC before the end of the period of 30 days beginning with the date on which notice of the assessment under paragraph 18 was issued.
(3) Subject to sub-paragraph (4), the provisions of Part 5 of TMA 1970 relating to appeals have effect in relation to appeals under this paragraph as they have effect in relation to an appeal against an assessment to income tax.
(4) On an appeal under this paragraph that is notified to the tribunal, the tribunal may—
(a) if it appears that no liability to a penalty has arisen, set the assessment aside,
(b) if the amount assessed appears to be appropriate, confirm the assessment,
(c) if the amount assessed appears to be excessive, reduce it to such other amount (including nil) as the tribunal considers appropriate, or
(d) if the amount assessed appears to be insufficient, increase it to such amount not exceeding the permitted maximum as the tribunal considers appropriate.

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/23/paragraph/20 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-23/paragraph-20
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.