4

In a case where HMRC are requested to undertake a review by virtue of paragraph 121E11—

a

an appeal may not be made to an 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.