In paragraph 121G of Schedule 6 to FA 200010 (bringing of appeals), for sub-paragraph (4) substitute—

“(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.”.