is a question of the value of any land or of a lease of land, and

arises in relation to the taxation of chargeable gains (whether under capital gains tax or corporation tax) or in relation to a claim under the 1992 Act,

an appeal against an amendment of a self-assessment under section 9C of this Act or paragraph 30 of Schedule 18 to the Finance Act 1998;

an appeal against an amendment of a return under paragraph F9034 of Schedule 18 to the Finance Act 1998;

an appeal against a conclusion stated or amendment made by a closure notice under section 28A or 28B of this Act;

an appeal against an amendment of a partnership return under section 30B(1) of this Act;

an appeal against an assessment to tax which is not a self-assessment;

an appeal against F30a conclusion stated or amendment made by a closure notice under paragraph 7(2) of Schedule 1A to this Act relating to a claim or election made otherwise than by being included in a return;

an appeal against a decision contained in a F31closure notice under paragraph 7(3) of Schedule 1A to this Act disallowing in whole or in part a claim or election made otherwise than by being included in a return.

in relation to land in England and Wales, the F88Upper Tribunal;

in relation to land in Scotland, the Lands Tribunal for Scotland;

in relation to land in Northern Ireland, the Lands Tribunal for Northern Ireland.

“appeal” means any appeal under the Taxes Acts;

a reference to notice of appeal given, or to be given, to HMRC is a reference to notice of appeal given, or to be given, under any provision of the Taxes Acts.

an appeal other than an appeal against an assessment, the following provisions of this Part of this Act shall, in their application to the appeal, have effect subject to any necessary modifications, including the omission of F91sections 54A to 54C and 56 below;

notice of appeal may be given to HMRC, but

no notice is given before the relevant time limit.

HMRC agree, or

where HMRC do not agree, the tribunal gives permission.

the appellant may notify HMRC that the appellant requires HMRC to review the matter in question (see section 49B),

HMRC may notify the appellant of an offer to review the matter in question (see section 49C), or

the appellant may notify the appeal to the tribunal (see section 49D).

the appellant has already given a notification under this section in relation to the matter in question,

HMRC have given a notification under section 49C in relation to the matter in question, or

the appellant has notified the appeal to the tribunal under section 49D.

the period of 30 days beginning with the day on which HMRC receive the notification from the appellant, or

such longer period as is reasonable.

HMRC have already given a notification under this section in relation to the matter in question,

the appellant has given a notification under section 49B in relation to the matter in question, or

the appellant has notified the appeal to the tribunal under section 49D.

HMRC have given a notification of their view of the matter in question under section 49B, or

HMRC have given a notification under section 49C in relation to the matter in question.

by HMRC in deciding the matter in question, and

by any person in seeking to resolve disagreement about the matter in question.

upheld,

varied, or

cancelled.

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

such other period as may be agreed.

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,

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

notice of appeal has been given to HMRC under paragraph 22(b) of Schedule 24 to the Finance Act 2021 in respect of a penalty, and

HMRC are required to review the matter in question under section 49B or 49C (which apply to the appeal by virtue of paragraph 23(1) of that Schedule).

upheld, or

cancelled.

it was concluded on an earlier review under section 49B or 49C that HMRC's view that the appellant was liable to the penalty point was to be upheld, or

HMRC's decision that the appellant was liable to the penalty point has been affirmed on appeal.

references to the appeal under paragraph 22(b) of that Schedule are to be read as references to the review under section 49B or 49C (as the case may be),

references to the tribunal are to be read as references to HMRC, and

references to cancelling a decision are to be read as references to concluding that HMRC's view is to be cancelled.

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

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

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

HMRC have offered to review the matter in question (see section 49C), and

the appellant has not accepted the offer.

“matter in question” means the matter to which an appeal relates;

a reference to a notification is a reference to a notification in writing.

notification of HMRC’s view under section 49B(2);

notification by HMRC of an offer of review (and of their view of the matter) under section 49C;

notification of the conclusions of a review under section 49E(6); and

notification of the conclusions of a review under section 49E(9).

that, F32... , the appellant is overcharged by a self-assessment;

that, F33... , any amounts contained in a partnership statement are excessive; or

that the appellant is overcharged by an assessment other than a self-assessment,

that the appellant is undercharged to tax by a self-assessment F34... ;

that any amounts contained in a partnership statement F35... are insufficient; or

that the appellant is undercharged by an assessment other than a self-assessment,

assesses an amount which is chargeable to tax, and

charges tax on the amount assessed,

the partner’s return under section 8 or 8A of this Act, or

the partner’s company tax return,

sections 9 to 14 of the TCEA 2007,

Tribunal Procedure Rules, and

the Taxes Acts.

the preceding provisions of this section shall not apply unless the fact that an agreement was come to, and the terms agreed, are confirmed by notice in writing given by the inspector or other proper officer of the Crown to the appellant or by the appellant to the inspector or other proper officer; and

the references in the said preceding provisions to the time when the agreement was come to shall be construed as references to the time of the giving of the said notice of confirmation.

a person who has given a notice of appeal notifies the inspector or other proper officer of the Crown, whether orally or in writing, that he desires not to proceed with the appeal; and

thirty days have elapsed since the giving of the notification without the inspector or other proper officer giving to the appellant notice in writing indicating that he is unwilling that the appeal should be treated as withdrawn,

no objection is made to the notification within 60 days after its date of issue, or such further period as may be allowed under section 54B(4) and (5), or

an objection is made but is withdrawn by the objector by notice.

an objection is made to the notification within 60 days after its date of issue, or such further period as may be allowed under section 54B(4) and (5),

the appropriate officer and the objector come to an agreement that the amount notified should be varied in a particular manner, and

the officer confirms that agreement in writing.

of the amount on which the tax is charged, or

of an alteration in an amount previously notified under paragraph (a) or this paragraph.

state its date of issue, and

state that the person notified may object to the notification by notice given within 60 days after that date.

the officer gives consent in writing.

in Great Britain, of the Department for Work and Pensions, and

in Northern Ireland, of the Department for Social Development.

a conclusion stated or amendment made by a closure notice under section 28A or 28B of this Act,

an assessment to tax other than a self-assessment,

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

by the amendment or assessment, or

where the appeal is against a conclusion stated by a closure notice, as a result of that conclusion,

first apply by notice in writing to HMRC within 30 days of the specified date for a determination by them of the amount of tax the payment of which should be postponed pending the determination of the appeal;

where such a determination is not agreed, refer the application for postponement to the tribunal within 30 days from the date of the document notifying HMRC’s decision on the amount to be postponed.

there is a change in the circumstances of the case as a result of which either party has grounds for believing that the amount so determined has become excessive or, as the case may be, insufficient, and

the parties cannot agree on a revised determination,

in the case of a determination made on an application under subsection (3) above, other than an application made by virtue of subsection (3A) above, the date on which any tax the payment of which is not so postponed is due and payable shall be determined as if the tax were charged by an F20amendment or assessment notice of which was issued on the date of that determination and against which there had been no appeal; and

the agreement is in writing, or

the understated tax to which the payment specified in the notice under section 220(2)(b) of that Act relates,

the disputed tax specified in the notice under section 221(2)(b) of that Act, F98...

the understated partner tax to which the payment specified in the notice under paragraph 4(1)(b) of Schedule 32 to that Act relatesF99, F101...

any amount of tax specified in the notice by virtue of an amendment made under section 227(7A) of that Act, or

if no representations were made under section 222 of that Act in respect of the notice, on or before the last day of the period of 90 days beginning with the day the notice or partner payment notice is given, and

the last day of the period of 30 days beginning with the day on which the notice is given, or

if later, the last day on which it would have been payable under subsection (8D) if it had been included in the amount specified in the accelerated payment notice or partner payment notice when that notice was given.

any tax overpaid shall be repaid.

the issue of the notice of amendment or assessment, or

in the case of an appeal against a conclusion stated or amendment made by a closure notice, the issue of the closure notice.

if too much tax has been paid, the amount overpaid shall be refunded with such interest, if any, as may be allowed by that order or judgment; and

if too little tax has been charged, the amount undercharged shall be due and payable at the expiration of a period of thirty days beginning with the date on which HMRC issue to the other party a notice of the total amount payable in accordance with the order or judgment.

an accelerated payment notice or partner payment notice has been given to a party to the appeal under Chapter 3 of Part 4 of the Finance Act 2014 (and not withdrawn), and

the assessment has effect, or partly has effect, to counteract the whole or part of the asserted advantage (within the meaning of section 219(3) of that Act) by reason of which the notice was given.

give permission to withhold all or part of any repayment, or

require the provision of adequate security before repayment is made.

as respects the conduct of appeals against assessments and decisions on claims under the F111992 Act,

entitling persons, in addition to those who would be so entitled apart from the regulations, F78to be parties to such appeals,

regulating the time within which such appeals or claims may be brought or made,

where the market value of an asset on a particular date, or an apportionment or any other matter, may affect the liability to capital gains tax of two or more persons, enabling any such person to have the matter determined by the tribunal having jurisdiction to determine that matter if arising on an appeal against an assessment, and prescribing a procedure by which the matter is not determined differently on different occasions,

authorising F79an officer of Revenue and Customs, notwithstanding the obligation as to secrecy imposed by virtue of this or any other Act, to disclose to a person entitled to appear on such an appeal the market value of an asset as determined by an assessment or decision on a claim, or to disclose to a person whose liability to tax may be affected by the determination of the market value of an asset on a particular date, or an apportionment or any other matter, any decision on the matter made by F79an officer of Revenue and Customs.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

provisions corresponding to section 563 of the Capital Allowances Act (determination of apportionment affecting tax liability of two or more persons), and

provisions authorising the giving of conditional decisions where, under F82section 46D of this Act or Tribunal Procedure Rules, F13. . . questions on an appeal against an assessment or a decision on a claim may go partly to one tribunal and partly to another.

shall be made by statutory instrument subject to annulment in pursuance of a resolution of the House of Commons, and

shall have effect notwithstanding anything in this Act.