SCHEDULES

SCHEDULE 33Annual tax on enveloped dwellings: returns, enquiries, assessments and appeals

PART 7Reviews and appeals

Late notice of appeal

37

1

This paragraph applies in a case where—

a

notice of appeal may be given to HMRC under this Schedule, but

b

no notice is given before the relevant time limit.

2

Notice may be given after the relevant time limit if—

a

HMRC agree, or

b

where HMRC do not agree, the tribunal gives permission.

3

HMRC must agree to notice being given after the relevant time limit if the appellant has requested in writing that HMRC do so and HMRC are satisfied—

a

that there was reasonable excuse for not giving the notice before the relevant time limit, and

b

that the request has been made without unreasonable delay.

4

If a request of the kind mentioned in sub-paragraph (3) is made, HMRC must notify the appellant whether or not HMRC agree to the request.

5

In this paragraph “relevant time limit”, in relation to notice of appeal, means the time before which the notice must to be given (disregarding this paragraph).