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25In section 8 (decisions by officers of HMRC), after subsection (1) insert—
“(1A)No decision in respect of Class 2 contributions under section 11(2) of the Social Security Contributions and Benefits Act 1992 may be made under subsection (1) in relation to an issue specified in paragraph (c) or (e) of that subsection if the person to whom the decision would relate—
(a)has appealed under Part 5 of the Taxes Management Act 1970 in relation to that issue,
(b)can appeal under that Part in relation to that issue, or
(c)might in the future, without the agreement of Her Majesty’s Revenue and Customs or permission of the tribunal, be able to appeal under that Part in relation to that issue.”
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