Oil Taxation Act 1975 section Sch 2 para 14F

Effect of conclusions of review

Paragraph 14F explains the legal effect of HMRC's review conclusions and how they become binding on the participator unless the matter is referred to a tribunal.

• When HMRC issue their conclusions following a review, those conclusions carry legal weight equivalent to a formal written settlement agreement between the participator and HMRC.
• The review conclusions are treated as though both parties had voluntarily agreed in writing to settle the disputed matter on those terms.
• This deemed agreement is overridden if the participator chooses to escalate the matter by notifying the appeal to the tribunal.
• The participator may challenge all or only part of the review conclusions by referring the relevant aspects to the tribunal.