Finance Act 2021

Bringing of appeals

10 (1) An appeal under paragraph 1 is to be made to the appeal tribunal before—

(a) the end of the period of 30 days beginning with—

(i) in a case where P is the appellant, the date of the document notifying P of the decision to which the appeal relates, or

(ii) in a case where a person other than P is the appellant, the day on which that person becomes aware of the decision, or

(b) if later, the end of the period for requiring a review (within the meaning of paragraph 6).

(2) But that is subject to sub-paragraphs (3) to (5).

(3) In a case where HMRC are required to undertake a review under paragraph 5—

(a) an appeal may not be made until the conclusion date, and

(b) any appeal is to be made within the period of 30 days beginning with that date.

(4) In a case where HMRC are requested to undertake a review under paragraph 7—

(a) an appeal may not be made to the appeal tribunal—

(i) unless HMRC have notified P, or the other person, as to whether or not a review will be undertaken, and

(ii) if HMRC have notified P, or the other person, that a review will be undertaken, until the conclusion date;

(b) any appeal where paragraph (a)(ii) applies is to be made within the period of 30 days beginning with the conclusion date;

(c) if HMRC have notified P, or the other person, that a review will not be undertaken, an appeal may be made only if the appeal tribunal gives permission to do so.

(5) In a case where paragraph 8(8) applies, an appeal may be made at any time from the end of the period specified in paragraph 8(6) to the date 30 days after the conclusion date.

(6) An appeal may be made after the end of any period specified in this paragraph if the appeal tribunal gives permission to do so.

(7) In this paragraph, “conclusion date” means the date of the document notifying the conclusions of the review.