If the Inland Revenue refuse to approve the scheme, the scheme organiser may appeal to the Special Commissioners.

The notice of appeal must be given to the Inland Revenue within 30 days after the date on which notice of their decision was given to the scheme organiser.

If the Special Commissioners allow the appeal, they may direct the Inland Revenue to approve the scheme with effect from a date specified by the Commissioners.

The date so specified must not be earlier than that of the application for approval.