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26(1)This paragraph applies where HMRC decide to impose a penalty under paragraph 25 on a person.
(2)HMRC must give the person notice of—
(a)their decision to impose the penalty and its amount,
(b)the reasons for imposing the penalty,
(c)the right to a review under this paragraph, and
(d)the right to appeal under paragraph 28.
(3)The person may by notice to HMRC require them to review their decision.
(4)A notice requiring a review may not be given after the end of the period of 45 days beginning with the day on which HMRC first gave the person notice under sub-paragraph (2).
(5)On a review under this paragraph, HMRC must either—
(a)confirm the decision, or
(b)withdraw or vary the decision and take such further steps (if any) in consequence of the withdrawal or variation as they consider appropriate.
(6)Where HMRC do not, within the period of 45 days beginning with the day the notice under sub-paragraph (3) was given, give notice to the person of their determination of the review, they are to be taken to have confirmed their decision.
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