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57(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.
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