Taxes Management Act 1970 section 49I

Interpretation of sections 49A to 49H

Section 49I provides definitions and interpretive rules that apply across the tax appeal review provisions in sections 49A to 49H.

• The "matter in question" simply means the issue that is the subject of the appeal, and any "notification" must be in writing.
• References to the "appellant" generally include anyone acting on their behalf, such as a tax agent or accountant.
• However, certain formal notifications from HMRC — including their view of the matter, an offer of review, and the conclusions of a review — must be sent directly to the appellant personally.
• Where a notification must be sent to the appellant directly, HMRC may also send a copy to the person acting on the appellant's behalf, such as their agent.