Schedules
Schedule 14Administration of multinational top-up tax
Part 12Appeals and claims
57Reviews by HMRC
1
A review is to be conducted by HMRC if—
a
the appellant notifies HMRC that it requires HMRC to review the matter, or
b
HMRC offers to review the matter and the appellant accepts the offer within the period of 30 days beginning with the date of the offer (the “acceptance period”).
2
The appellant may not notify HMRC that the appellant requires HMRC to review the matter if—
a
the appellant has already done so in relation to the same matter,
b
HMRC has offered to review the matter, or
c
the appellant has notified the appeal to the tribunal.
3
HMRC may not offer to review the matter if—
a
HMRC has already done so in relation to the same matter,
b
the appellant has notified HMRC that the appellant requires HMRC to review the matter, or
c
the appellant has notified the appeal to the tribunal.
4
An offer by HMRC to review the matter must—
a
be made in writing, and
b
contain a statement of HMRC’s view of the matter.
5
If the appellant does not accept the offer within the acceptance period—
a
HMRC's view of the matter is to be treated as if it were contained in a settlement agreement under paragraph 61, but
b
the right to withdraw from such an agreement does not apply in relation to that notional agreement.
6
Sub-paragraph (5) does not apply to the matter if, or to the extent that, the appellant notifies the appeal to the tribunal.
7
The appellant may notify the appeal to the tribunal—
a
within the acceptance period;
b
after the end of that period only if the tribunal gives permission.