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Finance Act 2021
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Review out of time
7(1)This paragraph applies if—
(a)HMRC have offered a review of a decision under paragraph 3 and P does not accept the offer within the time allowed under paragraph 5(1)(b) or 6(3), or
(b)a person who requires a review under paragraph 4 does not notify HMRC within the time allowed under paragraph 4(2) or 6(3).
(2)HMRC must review the decision under paragraph 5 if—
(a)after the time allowed, P, or the other person, notifies HMRC in writing requesting a review out of time,
(b)HMRC are satisfied that P, or the other person, had a reasonable excuse for not accepting the offer or requiring a review within the time allowed, and
(c)HMRC are satisfied that P, or the other person, made the request without unreasonable delay after the excuse had ceased to apply.
(3)But HMRC shall not review a decision if P, or another person, has appealed to the appeal tribunal under paragraph 1 in respect of the decision.
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