Oil Taxation Act 1975 section 14E

Nature of review etc

Section 14E sets out how HMRC must conduct a review of a petroleum revenue tax matter, including the scope of the review, the timeframe for completion, and the possible outcomes.

• HMRC determine the appropriate nature and extent of the review, taking into account steps already taken by both HMRC and the participator to decide or resolve the matter before the review began.
• The review must consider any representations made by the participator, provided they are submitted early enough for HMRC to give them proper consideration.
• The review may conclude that HMRC's original view is upheld, varied, or cancelled, and HMRC must notify the participator of their conclusions and reasoning within 45 days (or an agreed alternative period).
• If HMRC fail to notify the participator of the review conclusions within the required timeframe, the review is automatically treated as having upheld HMRC's original view, and HMRC must notify the participator of that deemed conclusion.