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8(1)A person may appeal against a decision of HMRC that a penalty is payable by the person.U.K.
(2)An appeal under this paragraph is to be treated in the same way as an appeal against an assessment to, or determination of, the tax concerned (including by the application of any provision about bringing the appeal by notice to HMRC, about HMRC review of the decision or about determination of the appeal by the First-tier Tribunal or Upper Tribunal).
(3)Sub-paragraph (2) does not apply in respect of a matter expressly provided for by this Schedule.
(4)On an appeal under this paragraph, the tribunal may affirm or cancel HMRC's decision.