be given to HM Revenue and Customs at the address specified in the transfer notice within 30 days beginning with the date on which the transfer notice was served, and

specify the grounds of the appeal.

that the relevant PAYE debt (or part of the relevant PAYE debt) is not due from the managed service company to HM Revenue and Customs;

that the specified amount does not relate to a company which is a managed service company;

that the specified amount is not irrecoverable from the managed service company within a reasonable period;

that the transferee is not a person mentioned in section 688A(2);

that the transferee was not a person mentioned in section 688A(2) during the tax periods to which the specified amount relates;

that the transferee was not a person mentioned in section 688A(2) during some part of the tax periods to which the specified amount relates

that the transfer notice was not served before the end of the period specified in regulation 97D;

that the transfer notice does not satisfy the requirements specified in regulation 97E;

in the case of a transferee mentioned in section 688A(2)(c) or of a paragraph (c) associate, that it is not impracticable to recover the specified amount from persons mentioned in paragraphs (a) and (b) of section 688A(2) or from paragraph (b) associates;

in the case of a transferee mentioned in section 688A(2)(c) or of a paragraph (c) associate, that the amount specified in the transfer notice does not have regard to the degree and extent to which the transferee is a person who (directly or indirectly) has encouraged or been actively involved in the provision by the managed service company of the services of the individual mentioned in that provision.