TC09594 - [2025] UKFTT 00893 (TC)

Fecha: 02-Jul-2025

Conclusions

(6)

HMRC must notify the appellant of the conclusions of the review and their reasoning within—

(a)

the period of 45 days beginning with the relevant day, or

(b)

such other period as may be agreed.

(7)

In subsection (6) “relevant day” means—

(a)

in a case where the appellant required the review, the day when HMRC notified the appellant of HMRC's view of the matter in question,

(b)

in a case where HMRC offered the review, the day when HMRC received notification of the appellant's acceptance of the offer.

(8)

Where HMRC are required to undertake a review but do not give notice of the conclusions within the time period specified in subsection (6), the review is to be treated as having concluded that HMRC's view of the matter in question (see sections 49B(2) and 49C(2)) is upheld.

(9)

If subsection (8) applies, HMRC must notify the appellant of the conclusion which the review is treated as having reached.

49G— Notifying appeal to tribunal after review concluded

(1)

This section applies if—

(a)

HMRC have given notice of the conclusions of a review in accordance with section 49E, or

(b)

the period specified in section 49E(6) has ended and HMRC have not given notice of the conclusions of the review.

(2)

The appellant may notify the appeal to the tribunal within the post-review period.

(3)

If the post-review period has ended, the appellant may notify the appeal to the tribunal only if the tribunal gives permission.

(4)

If the appellant notifies the appeal to the tribunal, the tribunal is to determine the matter in question.

(5)

In this section “post-review period” means—

(a)

in a case falling within subsection (1)(a), the period of 30 days beginning with the date of the document in which HMRC give notice of the conclusions of the review in accordance with section 49E(6), or

(b)

in a case falling within subsection (1)(b), the period that—

(i)

begins with the day following the last day of the period specified in section 49E(6),

and

(ii)

ends 30 days after the date of the document in which HMRC give notice of the conclusions of the review in accordance with section 49E(9).

118 (2) For the purposes of this Act, a person shall be deemed not to have failed to do anything required to be done within a limited time if he did it within such further time, if any, as the Board or the tribunal or officer concerned may have allowed; and where a person had a reasonable excuse for not doing anything required to be done he shall be deemed not to have failed to do it unless the excuse ceased and, after the excuse ceased, he shall be deemed not to have failed to do it if he did it without unreasonable delay after the excuse had ceased.