Section 9Part 0 —
Appeal
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A relevant entity that has been notified of a determination of a failure to satisfy the economic substance test and has a penalty imposed pursuant to section 8 may, within twenty-eight days after the notification, appeal against the determination and penalty to the Grand Court and such appeal shall act as a stay on the enforcement of the penalty.
An appeal under this section may be made on questions of law or fact or both and the Grand Court may affirm or reverse the determination and penalty or substitute its own penalty for that imposed by the Authority.
A person upon whom a penalty is imposed may appeal against the penalty on the ground that liability to a penalty does not arise.
Cross References
- Section 8 of International Tax Co Operation Economic Substance Act
Reference to penalty imposed pursuant to section 8
Referenced By
- Section 8 — Failure to satisfy economic substance test
Reference to appeal under section 9