Paragraph 65

(1)

The appellant may apply to the tribunal for a direction if—

(a)

the appellant has applied to HMRC for a determination,

(b)

HMRC has made a determination, and

(c)

the appellant does not agree with the determination.

(2)

The tribunal may direct whether the determination of HMRC was correct.

(3)

A decision of the tribunal under this paragraph is final and conclusive (despite the provisions of sections 12 and 15 of the Tribunals, Courts and Enforcement Act 2007).