Proceedings concerning late notice of review
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22.—(1) A person may apply to the First-tier Tribunal to be allowed a late notice of review under section 236(2)(b) of RSTPA 2014 (late notice of review) only if—
(a)the person has approached Revenue Scotland for agreement under section 236(2)(a); and
(b)agreement has been refused or has been given only on limited grounds.
(2) Where permission to be allowed a late notice of review is sought under paragraph (1), the notice of review must include a request for the permission referred to in section 236(2)(b) of RSTPA 2014 and the reason why the notice of review was not provided in time.