Oil Taxation Act 1975 section 14C

HMRC offer review

Paragraph 14C sets out the procedure that applies when HMRC offer to review a disputed petroleum revenue tax matter, including the time limit for acceptance and the consequences of not responding.

  • When HMRC offer a review, they must at the same time tell the participator what HMRC's view of the disputed matter is.
  • The participator has 30 days from the date of HMRC's offer letter to accept the review; if accepted, HMRC must carry out the review in accordance with the prescribed review procedure.
  • If the participator does not accept the offer within 30 days, HMRC's stated view is treated as a binding written settlement agreement โ€” unless the participator instead notifies the appeal to the tribunal.
  • HMRC cannot offer a review if they have already done so for the same matter, or if the participator has already requested a review or notified the appeal to the tribunal.

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