Taxes Management Act 1970 section 49F

Effect of conclusions of review

Section 49F explains what happens once HMRC have completed a review and issued their conclusions, and how those conclusions are treated for the purposes of settling an appeal.

• Once HMRC issue the conclusions of a review, those conclusions are automatically treated as a binding written settlement agreement between the parties.
• Unlike a normal settlement agreement, the appellant has no right to withdraw from or reject the deemed agreement.
• However, the deemed settlement agreement does not take effect if the appellant refers the appeal to the tax tribunal.
• The appellant therefore has a choice: accept the review conclusions as final, or escalate the matter to the tribunal.