Section 84(7)

Where there is an appeal against a decision to make such a direction as is mentioned in section 83(1)(u), the tribunal shall not allow the appeal unless it considers that HMRC could not reasonably have been satisfied as to the matters in sub-paragraph (2)(a) to (d) of paragraph 2 of Schedule 1 or, as the case may be, that there were grounds for making the direction.

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Source: legislation.gov.uk · retrieved 2026-07-28