“(4)

In a case where HMRC are requested to undertake a review in accordance with section 83E7—

(a)

an appeal may not be made—

(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 tribunal gives permission to do so.”.