art 20 Appeals against variable monetary penalties
(1) The person on whom a variable monetary penalty is imposed may appeal against the decision as to the imposition or amount of the penalty. (2) The grounds of appeal areβ (a) that the decision was based on an error of fact; (b) that the decision was wrong in law; (c) that the amount of the penalty is unreasonable; (d) that the decision was unreasonable for any other reason; (e) any other reason permitted by the First-tier Tribunal.