Taxes Management Act 1970 section 49C

HMRC offer review

Section 49C deals with the process and consequences when HMRC offers to review a matter under appeal, including the time limits for accepting the offer and what happens if the taxpayer does not respond.

• When HMRC offers a review, they must at the same time tell the appellant what HMRC's view of the matter is.
• The appellant has 30 days from the date of HMRC's offer letter to accept; if they accept, HMRC must carry out a formal review of the matter.
• If the appellant does not accept within 30 days and does not refer the appeal to the tribunal, HMRC's stated view is automatically treated as a binding written settlement agreement that the appellant cannot withdraw from.
• HMRC cannot offer a review if they have already done so, the appellant has already requested a review, or the appellant has already notified the appeal to the tribunal.