114Refusal to issue certificate and appeal against refusalU.K.
(1)This section applies if, on an application for a certificate under section 113, the Inland Revenue are not satisfied that the applicant has provided them with the information and documents required by or under subsection (2) of that section.
(2)The Inland Revenue must give written notice (“the refusal notice”) to the applicant of their refusal to issue a certificate.
(3)The refusal notice must specify the reasons for the refusal.
(4)The applicant may by written notice (“the appeal notice”) appeal to the Special Commissioners against the refusal.
(5)The appeal notice must be given to the Inland Revenue within 30 days of the date of the refusal notice.
(6)Part 5 of the Taxes Management Act 1970 (c. 9) (appeals and other proceedings) shall apply in relation to an appeal under this section.
(7)On the appeal, the Special Commissioners may—
(a)confirm the refusal notice, or
(b)quash it and require the Inland Revenue to issue a certificate.