Finance (No.2) Act 1987

7 Notice of the giving of a direction under paragraph 5 or paragraph 6 above shall be given to the dual resident investing company concerned; and any company to which such a notice is given may, by giving notice of appeal in writing to the Board within sixty days of the date of the notice given to the company, appeal to the Special Commissioners against the direction on either or both of the following grounds,—

(a) that the conditions applicable to the company under sub-paragraph (2) or sub-paragraph (3) of paragraph 5 above are not fulfilled or, as the case may be, that neither of the conditions in paragraph 6(1) above is fulfilled;

(b) that the sole or main benefit that might be expected to accrue from the early payment or, as the case may be, the arrangements was not that stated in paragraph 5(4) or, as the case may be, paragraph 6(2) above.